1 FERNALD LAW GROUP APC Brandon C. Fernald (Bar No. 222429) 2 Adam P. Zaffos (Bar No. 217669) Address: 510 W 6th Street, Suite 700 3 Los Angeles, California 90014 Telephone: (323) 410-0300 4 Facsimile: (323) 410-0330 E-Mail: [email protected] 5 [email protected]

6 Attorneys for Plaintiff DR. IMAN SADEGHI 7

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 DR. IMAN SADEGHI, an individual, Case No.:

12 Plaintiff, VERIFIED COMPLAINT FOR DAMAGES AND DECLARATORY RELIEF: 13 v. 1. Fraud and Deceit 14 2. Assault and Battery 15 PINSCREEN, INC., a Delaware Corporation; 3. Violation of Cal. Labor Code § 1102.5 - DR. HAO LI, an individual; Retaliation Against Whistleblowing 16 and DOES 1 through 100, 4. Breach of Contract

17 5. Breach of Implied Contract 6. Breach of Implied Covenant of Good Faith 18 Defendants. and Fair Dealing

19 7. Wrongful Termination in Violation of Cal. Public Policy 20 8. Intentional Interference with Contract 21 9. Negligent Hiring, Supervision or Retention 10. False Imprisonment 22 11. Invasion of Privacy 23 12. Conversion 13. Negligence 24 14. Intentional Infliction of Emotional Distress 25 15. Violation of Cal. Labor Code § 2802 16. Violation of Cal. Unfair Competition Law 26 (UCL), Bus. & Prof. Code § 17200 et seq. 17. Declaratory Relief 27

28 DEMAND FOR JURY TRIAL

VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Plaintiff Dr. Iman Sadeghi (“Sadeghi”), alleges the following against defendants Pinscreen, 2 Inc. (“Pinscreen”), Dr. Hao Li (“Li”), and Does 1-100. 3 CASE SUMMARY 4 1. Sadeghi earned a doctorate in Computer Science/Computer Graphics from 5 University of California, San Diego (“UCSD”). He developed, published, and patented a novel 6 digital hair appearance framework for Walt Disney Animation Studios’ movie Tangled and has 7 presented his work in prestigious scientific forums. After having worked at Google as a Software 8 Engineer for more than five years, Sadeghi was solicited by Pinscreen to join the company’s 9 leadership. 10 2. Pinscreen is a software start-up specializing in automatically generating animated 3D 11 face models, called avatars, using only a photograph of a person. Li, an assistant professor at 12 University of Southern California (“USC”), is one of the co-founders and the Chief Executive 13 Officer (“CEO”) of Pinscreen. 14 3. Defrauding Sadeghi, Pinscreen, through Li, knowingly misrepresented Pinscreen’s 15 avatar generation capabilities to Sadeghi and concealed its various illegal practices from him. 16 Pinscreen’s and Li’s unlawful conduct involved a variety of fraudulent activities including 17 misrepresenting manually prepared avatars as automatic, which is at the heart of Pinscreen’s 18 technical claims. 19 4. In reliance on Li’s fraudulent misrepresentations to him, Sadeghi resigned from 20 Google and joined Pinscreen as its VP of Engineering. While working to improve the quality of 21 Pinscreen’s infrastructure and avatars, Sadeghi gradually discovered Li’s and Pinscreen’s data 22 fabrication and academic misconduct. When confronted by Sadeghi, Li asserted that Pinscreen 23 would achieve its inflated claims in time for subsequent publications, which Li considered to be 24 crucial for Pinscreen’s industry exposure and success. Li promised Sadeghi that Pinscreen would 25 never fabricate its results in public representations. 26 5. Li broke this promise on August 1, 2017, when Pinscreen and Li publicly 27 mispresented fabricated avatars on the stage of SIGGRAPH 2017 Real-Time Live (“RTL”) to an 28 audience of thousands. In retaliation for Sadeghi’s objections and whistleblowing regarding Li’s 2 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 data fabrication, academic misconduct, labor law violations, and other unlawful practices, Pinscreen 2 illegally terminated Sadeghi, on August 7, 2017, within Sadeghi’s first working hour after 3 Pinscreen’s fabricated demo at RTL. 4 6. On the day of the wrongful termination, Li and Pinscreen committed multiple other 5 torts against Sadeghi, such as false imprisonment, assault and battery. As a result of the battery, 6 Sadeghi has suffered severe physical, mental and emotional distress as well as physical injuries 7 requiring medical treatments. 8 7. Following the wrongful termination, Pinscreen committed additional breaches of 9 contract and engaged in other unlawful conduct, such as withholding business expense 10 reimbursements, refusing to pay due penalties for late wage payments for nearly a year, damaging 11 Sadeghi’s personal property, invasion of his privacy, and conversion of his personal data. 12 8. Sadeghi brings this action to vindicate his legal rights, and more importantly, to 13 benefit the public; to preserve the integrity of scientific research; to safeguard Computer Science, 14 Computer Graphics, and SIGGRAPH communities; and to protect Pinscreen’s employees and 15 investors, while preventing Li, Pinscreen, and other defendants from engaging in further unlawful 16 practices. 17 THE PARTIES 18 9. Sadeghi is an individual who, at all times relevant to the Complaint, resided in 19 Marina del Rey, in the County of Los Angeles, in the State of California. Sadeghi was employed by 20 Pinscreen in the County of Los Angeles, in the State of California from February 2, 2017 to August 21 7, 2017. 22 10. Sadeghi alleges, on information and belief, that Pinscreen is, and at all times 23 mentioned was, a Delaware corporation with its principal place of business in the County of Los 24 Angeles in the State of California. 25 11. Sadeghi alleges, on information and belief, that Li is, and at all times mentioned was, 26 an individual residing in the County of Los Angeles in the State of California and was and is the 27 Chief Executive Officer (“CEO”), and a co-founder of Pinscreen. 28 12. Sadeghi alleges, on information and belief, that Does 1 through 100 participated in 3 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 the wrongful acts alleged and are liable for those acts. Sadeghi is informed and believes that Does 2 1 through 100 knew and participated in one or more of the specific acts committed by the defendants. 3 13. Sadeghi alleges, on information and belief, that in doing the acts alleged, each of the 4 defendants were the agent, principal, employee, or alter ego of one or more of the other defendants 5 and acted with the other defendants’ knowledge, consent, and approval. Each of the defendants is 6 responsible for the liabilities of the other defendants. 7 JURISDICTION AND VENUE 8 14. This Court has jurisdiction over the subject matter because, on information and 9 belief, each defendant is either a resident of California, has sufficient minimum contacts in 10 California, or otherwise intentionally avails themselves of the California market. The nature of the 11 claim as well as the amount in controversy, as delineated within this Complaint, meet the 12 requirements for the unlimited jurisdiction of this Court. 13 15. Venue is proper in this Court because, on information and belief, Pinscreen resides, 14 transacts business, and has offices in the County of Los Angeles, and most of the unlawful practices 15 that caused Sadeghi’s damages as alleged herein occurred in the County of Los Angeles. 16 FACTS RELATED TO CAUSES OF ACTION 17 Sadeghi’s Qualifications 18 16. Sadeghi earned his B.Sc. degree in Computer Engineering, in 2006, and graduated 19 first in class from Sharif University of Technology. Shortly after, Sadeghi started graduate school 20 at the University of California, San Diego (“UCSD”) in the field of Computer Science. 21 17. In 2007, Sadeghi was awarded the Grand Prize in UCSD’s Rendering Competition. 22 Rendering is the process of automatically generating the appearance of digital objects using 23 computers. In 2008, Sadeghi collaborated with Walt Disney Animation Studios (“Disney”) on hair 24 rendering (i.e. digital hair appearance) and received his M.Sc. degree in Computer 25 Science/Computer Graphics, on the topic. (Exhibits A1, A2) 26 18. Sadeghi worked at Disney during 2008 and 2009 and developed a novel hair 27 rendering framework for the production of the movie Tangled. In 2010, Sadeghi presented the 28 framework at the SIGGRAPH conference, considered by many to be the most reputable conference 4 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 in the field of Computer Graphics. Sadeghi also holds a patent on the framework together with 2 Disney. The following figure features some of the results of the hair rendering framework: (Exhibits 3 A2, A3, A4) 4 5 6 7 8

9 19. Li later introduced Sadeghi as “the guy behind all the hair rendering technology for 10 Disney and DreamWorks (including Tangled)” and, on information and belief, referred to Sadeghi 11 as “the best hair rendering guy.” (Exhibits A5, A6) 12 13 14

15 … 16

17 20. In 2010, Sadeghi worked at Industrial Light & Magic (“ILM”) and became 18 acquainted with Li. On information and belief, Li was attending graduate school also in the field of 19 Computer Graphics. Sadeghi and Li stayed in touch over the years and considered each other “good 20 friends.” (Exhibits A7, A8) 21 21. On June 11, 2011, Sadeghi was ceremonially honored when he received his Ph.D. 22 from UCSD in Computer Science/Computer Graphics. Later, Sadeghi presented his scientific 23 research from his Ph.D. dissertation, in the field of rendering and appearance modeling, at 24 SIGGRAPH 2012 and SIGGRAPH 2013. (Exhibits A9, A10, A11) 25 22. Sadeghi joined Google as a Software Engineer, on August 15, 2011, and over the 26 years, gained experience with Robust Software System Architectures, Reliable Scalable Distributed 27 Systems, Deep Convolutional Neural Networks, and among other achievements holds multiple 28 patents together with Google. 5 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 23. On information and belief, Li received his M.Sc. from Universität Karlsruhe in 2006, 2 received his Ph.D. from Eidgenössische Technische Hochschule Zürich (“ETH Zurich”) in 2010, 3 became an assistant professor at University of Southern California (“USC”) in 2013, co-founded 4 Pinscreen in 2015, and solicited Sadeghi to join Pinscreen’s leadership in 2016. 5 24. Li praised Sadeghi and told him, “I do believe that you will bring a lot to the 6 company,” “I think if you join us, you would bring a lot of energy with you,” and that “you bring in 7 exceptional potential, knowledge and leadership.” Li told Sadeghi that he thinks various Pinscreen 8 stakeholders “like you a lot,” “think you are awesome,” that “they really like you and we really want 9 you to join us” and that “we have been really impressed by you and are very thrilled with the 10 possibility of having you.” (Exhibits B6, B8, B9, B14, B15, B16) 11 25. Even on the last day of Sadeghi’s employment at Pinscreen, on August 7, 2017, Li 12 praised Sadeghi and told him: 13 26. [August 7, 2017] Li: “You bring a lot of positive energy and did a lot of things that 14 brought us so far.” 15 27. [August 7, 2017] Li: “As a person I really think you bring the most to this company.” 16 28. [August 7, 2017] Li: “I think you have charisma, you bring a lot of people to work 17 together, you motivate people. People like you as a person.” 18 Li’s and Pinscreen’s Solicitation of Sadeghi 19 29. In early October of 2016, during a scientific conference in Amsterdam, Netherlands, 20 Li, as the Chief Executive Officer (“CEO”) and a co-founder of Pinscreen, approached Sadeghi and 21 invited him to join the company, which Li followed up on in writing in November of 2016. Li’s 22 continual attempts to persuade Sadeghi to join Pinscreen lasted until late January of 2017. (Exhibits 23 B1, B2, B3, B4, B7, B12, B13, B17) 24 30. Li offered Sadeghi the “leadership role” of “VP of Engineering” and described it as 25 “potentially having a more important role than CTO [Chief Technology Officer].” Li told Sadeghi 26 that his responsibilities would be to “make sure other people work,” “coordinate teams and also 27 ensure efficient deliverables,” and to “oversee the technology development of everyone and push it 28 to the next level.” (Exhibits B18, B19) 6 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 31. In response to Sadeghi’s concern for potential risks, Li stated “I don’t think there are 2 any risks” for Sadeghi in joining Pinscreen, and that “I’m quite sure the reward is bigger than with 3 the other companies, not only in terms of impact but also financially.” (Exhibits B10, B12) 4 32. After claiming that “for startup at our stage the biggest benefit is in stock options,” 5 Li offered Sadeghi 2.3% of Pinscreen’s shares. Sadeghi’s employment contract stated that Pinscreen 6 shall provide Sadeghi equity awards equal to 2.3% ownership of Pinscreen over a four-year vesting 7 period, plus additional stock options to “counteract the dilutive effect” of company’s Series A round 8 of financing on Sadeghi. (Exhibits B5, B11, B20, G) 9 33. Li repeatedly implied long-term plans for Sadeghi’s employment. For instance, on 10 December 18, 2016, Li wrote to Sadeghi, “I believe we can do amazing work together and […] build 11 a successful company together,” “we hope that you join our journey, being part of the first 12 employees,” “as we move to the next rounds of fundings [sic] and growth, the value of the company 13 is likely to increase significantly, so you would be joining at a great time now.” Additionally, on 14 February 18, 2017, Li re-emphasized on the long-term vision for Sadeghi’s employment and wrote 15 that “after four years, [Sadeghi] will get all of [his stock option shares].” (Exhibits B8, B21) 16 34. Li wrote on November 8, 2016 and December 26, 2016 that Pinscreen’s valuation 17 was $30 million. On a phone conversation, on February 21, 2017, Pinscreen’s counsel informed 18 Sadeghi that the company’s valuation was $57.5 million. Li stated on June 17, 2017 that, after the 19 investment agreement with Softbank Venture Korea (“Softbank”), Pinscreen's valuation had 20 increased to more than $100 million. (Exhibits B1, B11) 21 Pinscreen’s Technology and Terminology1 22 35. Pinscreen is a software start-up specializing in automatically generating animated 3D 23 face models, called avatars, using only an input image. Competitor companies include Loom.ai, 24 ObEN, and FaceUnity. 25 36. The following diagram demonstrates subprocesses of Pinscreen’s avatar generation 26 27 1 The facts and terminology in this section (paragraphs 35 through 49) are not reasonably in dispute 28 and are based on information and belief. 7 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 technology which are relevant to this complaint. Subprocesses marked with an asterisk ( * ) are 2 among the ones that Pinscreen has misrepresented. The Hair Appearance subprocess, marked with 3 an obelisk ( † ), is within Sadeghi’s expertise and was significantly improved by his contributions: 4 5 6 7 8 9

10 37. Relevant components of Pinscreen’s technology include the following:

11 38. Input Image: Digital photograph of a person used to generate the output avatar. 12 39. Hair Shape* or Hair Reconstruction*, Hair Fitting*: The process of automatically 13 estimating the shape of the hair (turquoise area) from the input image. This process has been 14 fabricated by Pinscreen multiple times.

15 40. Face Shape or Face Reconstruction, Face Fitting: The process of automatically 16 estimating the shape of the face (coral area) from the input image.

17 41. Hair Color*: The process of automatically estimating the hair color from the input 18 image. This process has been fabricated by Pinscreen.

19 42. Eye Color*: The process of automatically estimating the eye color from the input 20 image. This process has been fabricated by Pinscreen.

21 43. Hair Appearance† or Hair Rendering†, Hair Shading†: The process of 22 automatically generating the hair appearance from the estimated hair shape (turquoise area) and hair 23 color. As an expert in hair rendering, Sadeghi significantly improved the quality of Pinscreen’s 24 digital hair appearance.

25 44. Face Appearance: The process of automatically generating the appearance of the 26 face from the estimated face shape (coral area) and eye color. 27 45. Relevant terminology to this complaint includes the following:

28 46. Speed of Avatar Generation: The time it takes to generate an avatar in real-time. 8 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 47. Pre-Cached or Pre-Built Avatar: Avatar that has been previously generated. 2 48. Brand-New Avatar: Avatar generated from a brand-new input image, e.g. an image 3 from the webcam, which cannot be pre-cached and has to be generated in real-time.

4 49. Fabricated Avatar: Pinscreen’s avatar fabrication included:

5 • A manually prepared avatar misrepresented as automatic. 6 • A pre-cached avatar misrepresented as brand-new and/or in real-time. 7 Li’s and Pinscreen’s Fraud and Deceit of Sadeghi 8 50. Li deceived Sadeghi by intentionally misrepresenting Pinscreen’s technical 9 capabilities to Sadeghi and intentionally concealing its various illegal practices from him.

10 51. On information and belief, Li persuaded Sadeghi to join Pinscreen in order to gain 11 access to Sadeghi’s expertise and experience in digital hair appearance and software engineering. 12 52. On January 22, 2017, before Sadeghi had signed the contract to join Pinscreen, Li 13 sent him, in writing through Facebook messages, two examples of purportedly automatically 14 generated avatars. Sadeghi specifically inquired of Li as to whether the hair of the presented avatars 15 had been automatically generated (“autogenerated”), to which Li responded “yes.” (Exhibit C1) 16 53. Li’s claim that the presented avatars and their hair were automatically generated was 17 a brazen lie. Even up to six months after Li’s initial presentations to Sadeghi, Li and Pinscreen 18 repeatedly fabricated avatars in various representations, such as by falsely representing manually 19 prepared hair shapes as automatic. 20 54. For instance, Pinscreen falsely represented manually prepared hair shapes as 21 automatic in its SIGGRAPH RTL submission on April 4, 2017; SIGGRAPH Asia Technical Papers 22 submission on May 23, 2017; SIGGRAPH RTL public demo on August 1, 2017; as well as business 23 representations to investors including, on information and belief, Softbank. 24 55. Prior to Sadeghi’s signing the contract with Pinscreen, Li had further misrepresented 25 Pinscreen’s technical capabilities. For example, on December 26, 2016, Li claimed that Pinscreen 26 has built “a technology that is state of the art,” and on January 19, 2017, that Pinscreen has “high 27 quality hair.” (Exhibits C2, C3) 28 56. Shortly after Sadeghi joined the company, Li contradicted his prior claims on 9 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 multiple occasions. For instance, on March 1, 2017, Li evaluated various components of Pinscreen’s 2 technology, including the hair component as, pardon the language, “shit” or “complete crap,” and 3 on March 13, 2017, Li stated that, the “avatar hair reconstruction is shit.” In practice, the quality of 4 Pinscreen’s hair reconstruction (i.e. hair shape estimation) was poor enough that Pinscreen 5 repeatedly resorted to fabricating it. Additionally, Pinscreen’s hair rendering (i.e. hair appearance), 6 before Sadeghi’s contributions, was far from “high quality,” as confirmed by SIGGRAPH 7 conference reviewers, and was referred to as “primitive” in Pinscreen’s own statement. (Exhibits 8 C4, C5, D1, D2, D3) 9 57. Li also deceived Sadeghi by intentionally concealing that Li and Pinscreen were 10 involved in data fabrication, academic misconduct, and unlawful practices that Sadeghi learned 11 about only after resigning from Google and joining Pinscreen. 12 58. On January 23, 2017, after relying on Li’s misrepresentations, and after months of 13 negotiation, Sadeghi accepted an offer from Pinscreen and signed the contract to join the company 14 as its VP of Engineering. Sadeghi sent out his resignation letter to Google, on January 25, 2017, and 15 stated that his last day at Google would be on February 1, 2017. Sadeghi began working for 16 Pinscreen the next day on February 2, 2017, per Li’s request to have Sadeghi on board for a Public 17 Relations (“PR”) event. A strong justification for Sadeghi’s reasonable reliance on Li’s 18 misrepresentations was that Li, on information and belief, was and is an assistant professor at USC. 19 Li’s claims to have automated that which he had merely fabricated means that Li has committed 20 academic misconduct which, if discovered, could be subject to draconian punishment. (Exhibits 21 B11, G) 22 Sadeghi’s Contributions 23 Hair Appearance 24 59. During his employment at Pinscreen, Sadeghi significantly improved the quality of 25 Pinscreen’s avatars and digital hair appearance (i.e. hair rendering, or hair shading) from “below the 26 SIGGRAPH standard” to well above. 27 60. Pinscreen’s submission to SIGGRAPH Technical Papers, on January 16, 2017, prior 28 to Sadeghi’s employment, was rejected. One of the reasons for the rejection, given by the conference 10 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 reviewers, was the poor quality of Pinscreen’s avatars. One of the conference reviewers stated that 2 the quality of Pinscreen avatars were “below the SIGGRAPH standard,” that “a lot of disturbing 3 artifacts can be observed in almost all hair models” and that they “seriously doubt if the quality is 4 good enough for games or VR applications.” (Exhibit D1) 5 61. For the SIGGRAPH Asia Technical Papers submission, on May 23, 2017, Sadeghi 6 implemented a variation of his published hair appearance framework which significantly improved 7 the quality of Pinscreen’s avatars. This submission was consequently accepted. The quality 8 improvement in the submission was so significant that the conference reviewers asked Pinscreen for 9 an explanation on “why the quality is so improved comparing [sic] with previous submission?” 10 Pinscreen’s official response stated that “in this submission, hair shading has been significantly 11 improved using a variant of Sadeghi 2010 (used in Disney’s Tangled) and […].” (Exhibit D2) 12 62. The following diagram compares the quality of Pinscreen’s avatars before and after 13 Sadeghi’s contributions to Pinscreen’s digital hair appearance: (Exhibit D3)

14 Before After 15 Sadeghi’s Contributions to Sadeghi’s Contributions to Pinscreen’s Hair Appearance Pinscreen’s Hair Appearance 16 17 18 19 20 21 22 23 24 25

26 Pinscreen’s Submission to Pinscreen’s Submission to 27 SIGGRAPH on January 16, 2017 SIGGRAPH Asia on May 23, 2017 28 [Rejected] [Accepted] 11 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Hair Shape 2 63. Sadeghi also innovated an approach to use Deep Convolutional Neural Networks and 3 Artificial Intelligence (“AI”) to obtain Semantic Constraints for the hair (e.g. hair length, hair 4 curliness, etc.) from the input image in order to enhance the accuracy of the automatically estimated 5 hair shapes. (Exhibit D4) 6 64. In preparation for Pinscreen’s SIGGRAPH Asia 2017 publication, on April 18, 2017, 7 one of Pinscreen’s employees, who later became a first author of the publication, told Li that 8 Sadeghi’s approach for “Semantic Constraints could add biggest contribution” to the publication. 9 Li also considered Sadeghi’s approach to be a competitive edge and stated “we need to make sure 10 that people cannot easily implement it.” (Exhibit D5)

11 Infrastructure 12 65. Sadeghi improved Pinscreen’s core infrastructure through his contributions to its 13 System Architecture, Software Code Health, Software Codebase Structure, System Security, User 14 Interface/User Experience, and Mobile Apps Framework. (Exhibits D6, D7, D8, D9, D10, D11) 15 66. Sadeghi created the most comprehensive product description and roadmap for, on 16 information and belief, Pinscreen’s main product at the time, Pinmojis. Pinmoji, which stands for 17 Pinscreen Emoji, is a term Sadeghi coined and popularized within the company. (Exhibit D12)

18 Leadership 19 67. Sadeghi supervised individual employees, coordinated multiple teams, and planned 20 product launches and deliverables for Pinscreen. Sadeghi’s direct reports included Pinscreen’s Chief 21 Technology Officer (“CTO”). (Exhibits D13, D14, D15, D16) 22 68. During Sadeghi’s meeting with Li, on March 9, 2017, Li stated that Sadeghi was 23 “one of the most important hires for Pinscreen,” that Sadeghi “brought structure and energy to the 24 team” and that Li “couldn’t be happier” with Sadeghi’s employment. 25 69. Additionally, Sadeghi provided assistance and guidance to other Pinscreen 26 employees. For example, the day before his personal anniversary vacation, Sadeghi worked an 18- 27 hour shift, alongside another Pinscreen employee, to investigate an issue with computation of lights 28 described by Spherical Harmonics. In order to make sure that the issue was resolved, Sadeghi 12 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 worked overnight until after sunrise the next morning, on July 14, 2017, which enabled Pinscreen 2 to demonstrate dynamic lighting during its SIGGRAPH 2017 RTL demo. (Exhibit D17) 3 Li’s and Pinscreen’s Data Fabrication and Academic Misconduct 4 70. After joining Pinscreen, Sadeghi gradually realized that Li, although an assistant 5 professor, disrespected academics and was involved in data fabrication and various academic 6 misconduct. (Exhibit E1) 7 71. Li would embellish Pinscreen’s technical capabilities in scientific research 8 submissions and then use deadline pressure to overwork the employees to achieve his inflated 9 claims, and if the employees eventually failed, he would order them to fake the deliverables. 10 72. Li discussed ways to “tweak data to get the results we want” and referred to data 11 fabrication as “faking things,” “cheating,” “shitty cheating,” and “doing it manually.” Li mandated 12 data fabrication by stating that he “doesn’t think we can make it automatic,” that “we probably have 13 no choice but to cheat,” and that he thinks “it’s the only way.” (Exhibits E2, E3, E4, E5, E6, E7, E8) 14 73. [June 29, 2017] Li: “I’m really worried that nothing will work by [the] rehearsal and 15 we have to [do] some shitty cheating again.” 16 17 18 19

20 74. Li’s data fabrication and academic misconduct was a deception of the public, fraud 21 on company’s actual and potential investors, violation of scientific code of conduct, and a betrayal 22 to academics. On information and belief, these fabrications have resulted in scientific publications, 23 technical demos and news articles, which have given Pinscreen an advantage in the competitive 24 market by attracting millions of investor dollars to the company and away from its competitors. 25 (Exhibit E9) 26 75. On information and belief, Pinscreen employees, looked up to Li as a role model 27 when it came to conducting scientific research, including the ethics of it. Although these employees 28 knew about and, directly or indirectly, aided and abetted Li in misrepresenting Pinscreen’s avatar 13 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 generation results, Sadeghi is informed and believes and that without Li’s misguidance, the fakery 2 would not have occurred.

3 SIGGRAPH 2017 Technical Papers Submission 4 76. Shortly after joining Pinscreen, Sadeghi realized that under Li’s leadership, 5 Pinscreen included faked results in their SIGGRAPH Technical Papers submission, submitted on 6 January 16, 2017, prior to Sadeghi’s employment. Sadeghi alleges, based on information and belief, 7 that in that scientific research submission, among other misrepresentations, Pinscreen falsified 8 manually prepared hair shapes as automatically generated. This submission was eventually rejected 9 and later re-submitted to SIGGRAPH Asia 2017 Technical Papers. 10 77. When Sadeghi questioned Li about these misrepresentations, for instance on March 11 9, 2017, Li claimed that they were “not important” because the submissions were “not public.” Li 12 stated that Pinscreen had been practicing the strategy of “Fake it ‘til you make it” and declared that 13 “it has been working great.” Li claimed that should Pinscreen’s fabricated submissions be accepted, 14 Pinscreen would have sufficient time to actually develop the claims, by publication time. Li claimed 15 that it was crucial to the success of Pinscreen to get into these conferences for industry exposure. Li 16 stated that scientific publications and technical presentations would result in media coverage by 17 technology news outlets, such as TechCrunch, and will substantially “increase the valuation of the 18 company.” Li later claimed similar statements, writing “TechCrunch coverage should be our target.” 19 (Exhibit E10)

20 SIGGRAPH 2017 Real-Time Live Submission 21 78. In preparation for SIGGRAPH Real-Time Live (“RTL”) submission, due on April 4, 22 2017, Li wrote on a team thread, on March 27, 2017, that “the issue is that we don’t have time,” and 23 that “even if we fake things there is no time,” and that for the hair reconstruction (i.e. hair shape 24 estimation) “we probably have no choice but to cheat.” (Exhibits E3, E7) 25 26 27 28 14 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 … 4 5 … 6 7

8 79. Among other misrepresentations in the submission, on information and belief, Li 9 commissioned a freelance artist, located in Germany, named Leszek, to manually prepare the hair 10 shapes for all avatars presented in the submission. On March 30, 2017, Li stated that it would take 11 “3 hours” for an artist to create a hair shape and the cost would be “100 Euros.” Pinscreen 12 misrepresented these hair shapes as automatically generated, when in fact they were created through 13 this lengthy and expensive manual process. (Exhibit E11) 14 80. In the submission, Li also misrepresented Pinscreen’s speed of avatar generation as 15 “seconds”, which is a speed that Pinscreen was still unable to achieve nearly four months later, for 16 its SIGGRAPH RTL public demo, on August 1, 2017, where the true speed of avatar generation 17 was around a minute and a half. (Exhibit E12)

18 SIGGRAPH Asia 2017 Technical Papers Submission 19 81. Pinscreen revised its previously rejected submission to SIGGRAPH 2017 Technical 20 Papers and resubmitted it to SIGGRAPH Asia Technical Papers, on May 23, 2017. 21 82. For the resubmission, Pinscreen was asked to present 100 avatars for 100 input 22 images. (Exhibit E13) 23 83. Li commissioned artists to manually prepare hair shapes for the requested avatars 24 and falsely represented them as automatically generated in the submission. 25 84. Li stated, on April 18, 2017, “then I have an artist create 100 hairs ahahahaha,” and 26 on May 17, 2017, “basically, I need to create 3D hair models for 100 people or get 3D modelers to 27 do it.” (Exhibits E14, E15) 28 15 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4

5 … 6 7 8

9 85. Pinscreen also fabricated the process of estimating the eye color in the submission. 10 Li stated that the eye color estimation process was, pardon the language, “total shit,” “completely 11 random” and ordered Pinscreen employees to “manually fix all the eye colors” for the avatars. 12 Pinscreen then claimed in the publication that “several key components, such as […] eye color 13 recognition, are only possible due to recent advances in deep learning.” (Exhibits E6, E16, E17, 14 E18, E19, E20) 15 86. [May 15, 2017] Li: “Our eyes are wrong. The colors. We need to use a Deep Neural 16 [Network] for that […] Or we just do it manually for SIGGRAPH Asia for now […] Let’s do it 17 manually for now. I think it’s the only way.” 18 19 20

21 …

22 … 23 24

25 87. [May 18, 2017] Li: “The eye color is total shit. It’s completely random […] I would 26 say let’s do them manually for now.” 27 88. [May 18, 2017] Li: “Okay so I’m generating all the avatars. We need someone to 28 manually fix all the eye colors.” 16 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 … 4 5 … 6 7

8 89. In addition, Pinscreen fabricated the process of estimating the hair color in the 9 submission. A Pinscreen officer was assigned the task to “manually pick up hair color” for the

10 avatars. Pinscreen then fraudulently stated in the submission that “the eye color texture is computed 11 using a similar convolutional neural network […] as the one used for hair color classification.” 12 (Exhibits E21, E22) 13 90. On May 22, 2017, one day before the submission deadline, Li ordered the team, “if 14 in an hour it’s not working, let’s do it manually and give up on it. I don’t think we can make it 15 automatic.” 16 17 18 19 20 21 22

23 91. On May 23, 2017, Sadeghi confronted Li regarding the data fabrication and academic 24 misconduct committed in Pinscreen’s SIGGRAPH Asia 2017 Technical Papers submission. Li 25 stated that he wanted “Pinscreen to be the first” in research and the industry. Li claimed that by the 26 time of the conference, in November of 2017, Pinscreen would have had a public product launch 27 and would have achieved Li’s embellished claims in the submission. Sadeghi asked Li, “what if for 28 unforeseeable reasons we don’t have everything by then?” Li promised Sadeghi that Pinscreen’s 17 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 data fabrication would be limited to nonpublic representations and never shown in public and stated: 2 92. [May 23, 2017] Li: “We won’t present something we don’t have”

3 SIGGRAPH 2017 Real-Time Live Public Demo 4 93. Li considered SIGGRAPH Real-Time Live (“RTL”) as the “best event at 5 SIGGRAPH,” “the hardest thing to get in,” and “the only show that matters at SIGGRAPH.” Li 6 claimed that RTL gets “much more visibility than papers” and emphasized that “there will be 7 TechCrunch at SIGGRAPH RTL.” (Exhibits E10, E23) 8 94. However, as Pinscreen approached the RTL public presentation date of August 1, 9 2017, on information and belief, Li realized that Pinscreen would not be able to deliver on Li’s 10 inflated claims put forth in the submission, months earlier on April 4, 2017, despite Pinscreen 11 employees’ long hours and hard work. Li stated, on June 29, 2017, that he was “really worried that 12 nothing would work” by the RTL rehearsal and that Pinscreen would have to do “some shitty 13 cheating again.” (Exhibit E5) 14 95. The title that Li had chosen for the RTL demo was “Pinscreen: Creating Performance 15 Driven Avatars in Seconds.” In reality, however, Pinscreen’s avatar generation would take around 16 a minute and half to execute which was, on information and belief, comparable to the performance 17 of competitors such as Loom.ai. (Exhibit E24) 18 96. Additionally, the accuracy of Pinscreen’s hair shape estimation was far from Li’s 19 inflated claims in Pinscreen’s RTL submission since all purportedly automatic hair shapes were 20 instead manually prepared by freelance artists. 21 97. The allocated time for Pinscreen’s RTL demo was 6 minutes and Li planned to show 22 multiple avatar generations within 2 minutes. Sadeghi suggested that “if we don’t generate a brand- 23 new avatar,” the avatar can be cached. Pre-caching results, i.e., computing them beforehand and 24 storing them for quick access, is a common custom and practice while presenting technical demos 25 with limited time. However, the fact that an element is pre-cached should always be disclosed. 26 (Exhibit E25) 27 98. While Sadeghi was away on his personal anniversary vacation, Li decided to 28 misrepresent pre-cached avatars as real-time during Pinscreen’s RTL public demo, on August 1, 18 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2017, to an audience of thousands. In Sadeghi’s absence, Li revealed his intention to deceive the 2 RTL audience, in writing, on July 20, 2017, when he proposed on a team thread that Pinscreen 3 would “give the people the feeling the avatar is not pre-built” and that “we should give them a sense 4 that it is computing.” In reality, the avatars were pre-built and pre-computed. Li’s decision to 5 fabricate data in a public presentation was in violation of his earlier promise to Sadeghi. (Exhibit 6 E26) 7 8 9 10 11 12 13

14 99. On July 22, 2017, upon returning from his anniversary vacation, Sadeghi met other 15 Pinscreen employees at a scientific conference in Hawaii. Sadeghi tested Pinscreen’s avatar 16 generation and reported on a team thread that it took around a minute and half. Sadeghi’s report also 17 indicated that the automatically estimated hair shape was not accurate and represented a different 18 hairstyle. (Exhibit E27) 19 100. Shortly after, Sadeghi messaged Li to clarify Li’s plan to present a brand-new avatar 20 generation from the webcam at the RTL demo. Sadeghi informed Li that the speed of avatar 21 generation was around a minute and half and that there was “some risk for a hairstyle miss” meaning 22 inaccurate hair shape estimation. Li did not respond to Sadeghi’s message: (Exhibit E28) 23 24 25 26 27

28 19 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 101. Later that evening, on July 22, 2017, Sadeghi met with Li in person. Li disclosed his 2 plan to fabricate the webcam avatar generation and its speed by misrepresenting pre-cached 3 manually prepared avatars as brand-new, automatic, and real-time. Sadeghi confronted Li and stated 4 that Pinscreen should be truthful to the public and scientific community, that Li’s data fabrication 5 could be considered “investment fraud,” and that everyone’s “academic reputation” at Pinscreen 6 was at stake. 7 102. Li dismissed Sadeghi’s objections and claimed that the actual speed of Pinscreen’s 8 avatar generation was “too slow,” and that it “won't be impressive”, and therefore Pinscreen could 9 not present it. Li stated that one of his goals was to have “Loom.ai and ObEN to stop even trying to 10 compete with us.” Li expressed concerns that Pinscreen’s actual automatic hair shape estimation 11 could have poor quality and would “make us look bad” and claimed that “Loom.ai will laugh at us.” 12 Li later made similar statements to the team until a few days before the RTL demo. (Exhibit E29) 13 103. Li claimed that Pinscreen “didn’t have any other choice at that point,” that the 14 decision was made last week, that it was “final,” and that Sadeghi must follow the plan and focus 15 on finalizing the RTL demo. 16 104. Subsequently, Sadeghi asked Li to promise that moving forward, Pinscreen would 17 stay honest and avoid fabricating its results. Li dismissed Sadeghi’s request and stated, around 18 midnight on July 22, 2017: 19 105. Li: “Let’s talk about this after the RTL demo.” 20 106. Sadeghi reluctantly accepted Li’s proposal and focused on finalizing Pinscreen’s 21 RTL demo. 22 107. On July 24, 2017, a Pinscreen officer admitted in writing that Pinscreen was “just 23 using pre-cached avatars” and therefore “it’s important that we know exactly who is using the 24 webcam to generate the avatar”: (Exhibit E30) 25 26 27 28 20 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4

5 108. Li defined tasks such as “creating all avatars, hair models, tweak for perfect hair color” 6 and “hair models/avatars” and assigned them to one of Pinscreen’s employees. The employee 7 manually prepared the hair shapes for many of the avatars presented at RTL, including their own 8 avatar. On July 28, 2017, another employee requested “for my hair if you can lower it down a bit if 9 it’s not too hard, that would be nice. (I don’t think my forehead is that large).” The requested manual

10 modification of the hair shape was done after around 2 days: (Exhibit E31) 11 12

13 … 14 15 16 17 18 19 20 … 21 22 23 24

25 109. On August 1, 2017, during its SIGGRAPH RTL public demo, in front of thousands 26 of attendees and online viewers, Pinscreen misrepresented manually prepared hair shapes as 27 automatic, pre-cached avatars as brand-new and in real-time, and the speed of its avatar generation 28 of around a minute and half as around 5 seconds. 21 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 110. After receiving the “Notice of Claim and Litigation Hold” letter from Sadeghi’s 2 counsel, on November 2, 2017, Pinscreen announced inconsistent numbers for its speed of avatar 3 generation compared to what was misrepresented at SIGGRAPH 2017 RTL demo, which was 4 around 5 seconds. For instance, on November 14, 2017, Pinscreen announced that its avatar 5 generation requires around 4 minutes in its “high-quality” setting and that it takes “less than a 6 minute” without the high-quality features. (Exhibit E32) 7 111. Further evidence confirming Pinscreen’s data fabrication at RTL includes Li’s own 8 testimony. On November 29, 2017, during Pinscreen’s SIGGRAPH Asia 2017 Technical Papers 9 presentation in Thailand, Pinscreen stated that the hair shape estimation subprocess alone required 10 “less than 10 seconds.” After the presentation and during the Q&A session, Li was challenged about 11 Pinscreen’s demonstrated speed of avatar generation at RTL of around 5 seconds. Li was questioned 12 as to how the whole avatar generation process took around 5 seconds at RTL while one of the 13 subprocesses required around 10 seconds by itself. In response, Li blurted out that for RTL “we 14 definitely cached it.” When Li was subsequently questioned “the webcam was cached too?” Li 15 refused to answer the question, headed out of the Q&A session and proceeded to leave the 16 conference premises, on information and belief, to avoid answering the question.

17 Li’s Miscellaneous Data Fabrication and Academic Misconduct 18 112. Li’s academic misconduct included sharing confidential under-review scientific 19 paper submissions from competitor research groups within Pinscreen and suggesting to look for 20 “details that can be used.” (Exhibit E33) 21 113. Li made public claims about having scientific contributions to the iPhone X until a 22 Research Scientist from Apple Inc., the manufacturer of the iPhone X, posted on Li’s Facebook wall 23 on October 25, 2017, suggesting Li “to avoid propagating fake information.” (Exhibit E34) 24 114. Li’s data fabrication crossed over to business representations to investors and 25 Venture Capitalists (“VCs”), whom Li neither trusted nor respected. For instance, Li misrepresented 26 Pinscreen’s technical capabilities to Softbank, by falsely representing manually “picked” hair shapes 27 as automatic. Li disrespected Softbank, the day the investment agreement between the parties was 28 finalized, when he stated, pardon the language: (Exhibits E35, E36, E37) 22 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 115. [June 17, 2017] Li: “Pinscreen just fucked Softbank” 2 Li’s and Pinscreen’s Labor Law Violations 3 116. Li used deadline pressure to overwork Pinscreen employees and unlawfully refused 4 to pay them overtime. Li repeatedly asked for updates during the nights, weekends, and expected 5 student employees to work on holidays. For instance, on Father’s Day, Sunday, June 18, 2017, Li 6 wrote to Sadeghi and asked “please push the students more, they are getting lazy and only work half 7 of the day.” (Exhibit F1) 8 117. When Sadeghi questioned as to why there was a work-related event on Sunday, April 9 16, 2017, Li responded on a team thread, “we work every day.” 10 118. On June 28, 2017, Sadeghi told Li that some of Pinscreen’s non-exempt employees 11 were working an excessive amount of overtime and should be properly compensated. Li dismissed 12 Sadeghi’s proposal, telling him that “the students are used to working this many hours” and that 13 “the employees are salary based and are being paid enough already.” 14 119. Li told Sadeghi, in the same meeting, that “deadlines are a tool to push the students 15 to work more. Without deadlines they won’t work on the weekends and nights.” Li also suggested 16 Sadeghi to push Pinscreen employees to work more “as long as they don’t die from Karōshi.” 17 Karōshi is a Japanese term literally meaning “overwork death.” Another related Japanese term used 18 by Li was Salaryman which refers to employees who “are expected to work long hours, additional 19 overtime, […] and to value work over all else.” (Exhibits F2, F3) 20 120. While unlawfully refusing to pay overtime, Li posted on his Facebook about 21 overworked Pinscreen employees, who were passed out on couches inside Pinscreen’s office, 22 referring to them as “casualties.” Li referred to a Pinscreen employee as “Salariman [sic]” multiple 23 times. Li also publicly paid tribute to death from overwork, on his Facebook, by posting “Karoshi! 24 Let me tell you! Sleep is for the weak.” (Exhibits F4, F5, F6) 25 121. Sadeghi dined with two Pinscreen employees, on July 24, 2017, during a scientific 26 conference in Hawaii. During the dinner, they told Sadeghi about their excessive amount of overtime 27 work without receiving any financial compensation from the company. One of the employees further 28 stated that they “have no life” and that this amount of work “would not be sustainable.” Later, both 23 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 of the employees confirmed in writing that they had each worked, on average, around 110 hours per 2 week, for the months of May, June, and July of 2017. Sadeghi promised them he would talk to Li 3 after the RTL demo and try to persuade him to pay overtime and “to make sure we are fair to 4 everyone.” (Exhibits F7, F8) 5 122. Additionally, Li harassed and discriminated against a Pinscreen employee whom Li, 6 on information and belief, suspected to have Autism Spectrum Disorder. Li stated, on June 23, 2017, 7 that the employee “should not be autistic” and that it will be Li’s “new project” to teach him 8 “manners.” Li stated that the employee allegedly “does not have the ability to respond,” does not 9 behave “like an adult,” and that Li feels like he “is talking to a wall” when he is talking to the 10 employee. Li used demeaning language such as, pardon the language, “are you fucking shitting 11 me???” and “we are not fucking paying you for that!” when addressing the employee. Sadeghi 12 requested on June 28, 2017 that Li be respectful towards the employee, but Li dismissed Sadeghi’s 13 request, stating that the employee is “used to it” and that the demeaning language was how Li was 14 able to “push them to work more.” (Exhibit F9) 15 123. Furthermore, Li discussed firing Pinscreen’s CTO, while he was expecting a 16 newborn. Li claimed that if Li and Sadeghi do not check on the CTO, “he is just doing nothing,” 17 and that the CTO “is sick at every deadline we have.” Li stated that the CTO, “out of a sudden [sic] 18 had a child” and attributed CTO’s alleged lack of performance to having a baby. Sadeghi alleges, 19 on information and belief, that the CTO’s performance was indeed satisfactory and Li’s resentment 20 toward the CTO was because the CTO prioritized his family over work during the weekends. Li told 21 Sadeghi that the CTO was a “bad hombre” because “he doesn’t work on the weekends.” Li later 22 claimed, on May 23, 2017, that “[the CTO]’s baby has cost Pinscreen a shit ton of money.” In order 23 to clarify the CTO’s performance, Sadeghi suggested that Li ask the CTO to share detailed progress 24 reports with Li and Sadeghi. Furthermore, Sadeghi suggested that Li “make sure he [the CTO] 25 doesn't feel micromanaged or disrespected.” (Exhibits F10, F11) 26 Li’s and Pinscreen’s Retaliation and Wrongful Termination of Sadeghi 27 124. Since Li had promised to address Sadeghi’s concerns after Pinscreen’s SIGGRAPH 28 2017 RTL demo, Sadeghi requested, on Sunday, August 6, 2017, through e-mail, to set up a meeting 24 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 with Li “to talk about multiple important topics.” Li agreed to have the meeting the next day, on 2 Monday, August 7, 2017, at 5 p.m.: 3 125. [August 6, 2017] Sadeghi: “I would like to have a 1:1 meeting to talk about multiple 4 important topics. Are you free Monday or Tuesday night to talk over dinner?” 5 126. [August 6, 2017] Li: “Let’s meet at 5 p.m. in the office, we can discuss in the 6 conference meeting room.” 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

22 127. In Sadeghi’s meeting notes, titled “Pinscreen Concerns,” time-stamped by Google 23 servers prior to the meeting, Sadeghi referenced Pinscreen’s data fabrication during the SIGGRAPH 24 2017 RTL demo, and the SIGGRAPH Asia 2017 Technical Papers submission and stated that 25 Pinscreen “can be accused of illegal crime.” Sadeghi’s notes included that “these decisions to 26 promise things we don’t even have is coming from you [Li] and only you.” 27 128. Sadeghi’s meeting notes also contain a subsection regarding “overtime pay” with 28 examples of Pinscreen employees who, on information and belief, had worked around 110 hours 25 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 per week for three consecutive months, and did not receive overtime compensation from the 2 company, in violation of California labor laws. 3 129. On August 7, 2017, Li suggested to have the meeting immediately upon Sadeghi’s 4 arrival to Pinscreen’s office, instead of at 5 p.m. as previously planned. Sadeghi met with Li and 5 Pinscreen’s Chief Financial Officer (“CFO”) and reiterated his concerns about Li’s and Pinscreen’s 6 data fabrication and past due overtime payments. Sadeghi stated his objections regarding Li refusing 7 to properly compensate Pinscreen’s employees for overtime hours; Pinscreen “lying to thousands 8 of people” during its RTL demo; Li putting “everyone’s academic reputation” at risk; and Li 9 endangering Pinscreen’s investor relations due to the data fabrication. In response, moments before 10 Li handed Sadeghi his termination letter from Pinscreen, Li told Sadeghi: 11 130. [August 7, 2017] Li: “Maybe I don’t want to further damage your reputation.” 12 131. [August 7, 2017] Li: “I don’t think you need to worry about these anymore.” 13 132. Sadeghi received the termination letter within his first working hour after Pinscreen’s 14 fabricated RTL demo, which was during the meeting that Sadeghi had previously requested to 15 discuss “multiple important topics” regarding Li’s and Pinscreen’s unlawful activities. 16 133. During the meeting, Sadeghi requested to meet Pinscreen’s full board of directors 17 before the termination decision was final, to which Li responded, “sure.” 18 134. Neither Sadeghi’s termination letter nor his employment personnel file contain any 19 reasons for the termination nor do they indicate any concerns with Sadeghi’s performance. 20 135. Sadeghi alleges, on information and belief, that his termination was in retaliation for 21 his objections to Li regarding Li’s and Pinscreen’s illegal practices and in violation of California’s 22 whistleblowing protection laws provided in California Labor Code § 1102.5. 23 Defendants’ Assault and Battery on Sadeghi 24 136. Before Sadeghi had a chance to read the termination letter, Li suddenly lost his 25 temper, slammed the conference room door open and yelled at Sadeghi to leave the room, in front 26 of Sadeghi’s coworkers, in a humiliating and embarrassing manner. Li then attempted to physically 27 push Sadeghi out of the conference room in front of other Pinscreen employees. 28 137. [August 7, 2017] Sadeghi to Li: “You can’t touch me” 26 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 138. Concerned by Li’s aggressive behavior, Sadeghi decided to leave Pinscreen’s office, 2 however, Li physically blocked the door of the office and forcefully confined Sadeghi against his 3 will. Li demanded Sadeghi’s work laptop which was inside Sadeghi’s backpack which Sadeghi was 4 wearing. Li then attempted to take the laptop by force. 5 139. [August 7, 2017] Sadeghi to Li: “You are being aggressive” 6 140. [August 7, 2017] Pinscreen’s CFO to Li: “Let’s be calm. Let’s calm down. Calm 7 down.” 8 141. Sadeghi intended to return the laptop before the end of business day, on August 7, 9 2017, and told Li that he would return it after he preserved his personal data. Subsequently, Sadeghi 10 left Pinscreen’s office and headed towards the elevators. Li ordered some of Pinscreen’s employees 11 to follow Sadeghi. 12 142. After Sadeghi, Li, and other employees left the elevator, Sadeghi attempted to leave 13 the building through the lobby. However, Li and three other Pinscreen employees, under Li’s 14 commands, surrounded Sadeghi and physically attacked him. They grabbed Sadeghi and his 15 backpack, which he was wearing, violently restrained him, forcibly opened his backpack and took 16 possession of Sadeghi’s work laptop. 17 143. [August 7, 2017] Sadeghi to Li: “Don’t touch me. Don’t touch me.” 18 144. The battery, on information and belief, has been captured on the security cameras of 19 the building and the recordings have been preserved by the building security team. The security 20 officers on duty described the battery as Sadeghi being “grabbed,” “brought to the ground,” and 21 “taken to the ground” by Pinscreen employees. 22 145. During the battery, Sadeghi suffered injuries to his eye and his previously dislocated 23 shoulder, requiring medical attention and multiple physical therapy sessions. 24 146. Sadeghi has suffered severe mental and emotional distress as a result of the false 25 imprisonment, battery, and the consequent physical injuries. 26 147. Although multiple Pinscreen employees were involved with the battery, Sadeghi is 27 informed and believes that without Li’s orders, the other employees would not have participated in 28 committing the crime. 27 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Defendants’ Post Termination Violations 2 148. After Sadeghi’s wrongful termination, Pinscreen withheld business expense 3 reimbursements, in violation of Sadeghi’s employment contract and in violation of California Labor 4 Code § 2802. Pinscreen has subsequently acknowledged that the reimbursements were owed but 5 refused to pay them unless there was a successful settlement and/or mutual non-disclosure 6 agreement (“MNDA”). After more than nine months delay, Pinscreen paid only a small portion of 7 the past due reimbursements, in breach of Sadeghi’s contract and violation of prior written 8 agreements. 9 149. Additionally, Pinscreen delayed paying Sadeghi his final wage payments, which 10 according to California Labor Code § 203, entitled Sadeghi to waiting time penalties. Although, 11 Pinscreen sent Sadeghi a check for the late wage payment penalties in the amount of the waiting 12 time penalties owed, Pinscreen phrased the purpose of the check as a settlement offer “to resolve 13 any wage issues.” Sadeghi did not cash the check and requested Pinscreen, multiple times, to re- 14 issue another check for the waiting time penalties only, and to exclude the settlement agreement 15 verbiage. Pinscreen subsequently refused to do so and stated that re-issuing a check would be 16 “subject to execution of a mutually agreeable MNDA by and between Pinscreen and you [Sadeghi].” 17 After more than nine months delay, on May 23, 2018, Pinscreen re-issued a check for the past due 18 waiting time penalties. 19 150. Pinscreen damaged Sadeghi’s personal property remaining at Sadeghi’s desk at 20 Pinscreen’s office. In storing it negligently, Pinscreen broke Sadeghi’s handmade sculpture, which 21 has sentimental value. Sadeghi has demanded Pinscreen to reimburse him for the personal property 22 damages. Subsequently, Pinscreen has refused to do so and stated that such reimbursement would 23 be “subject to execution of a mutually agreeable MNDA” between Pinscreen and Sadeghi. 24 151. Pinscreen has illegally refused to return Sadeghi’s personal data that was stored on 25 his work laptop, which contained some of the only copies of Sadeghi’s personal anniversary trip 26 photos and videos, including explicit photos of himself. These photos were taken immediately prior 27 to Sadeghi’s work-related travel to a conference in Hawaii and temporarily stored on the laptop. 28 152. On August 7, 2017, after the battery on Sadeghi, when Pinscreen forcibly took 28 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 possession of Sadeghi’s work laptop, Li promised Sadeghi, “we will give you your personal files.” 2 Pinscreen has subsequently and unlawfully refused to do so. 3 153. Due to Li’s and Pinscreen’s violation of scientific research ethics and academic code 4 of conduct, Sadeghi requested the SIGGRAPH organization to retract his name from Pinscreen’s 5 fabricated publications. Li’s fraud against the scientific community and academic misconduct were 6 the proximate cause of Sadeghi having to sacrifice the scientific credit for his own significant 7 contribution to these publications. 8 154. Sadeghi has suffered severe mental and emotional distress as a result of the invasion 9 of his privacy, conversion of his personal data, and infringement of his intellectual property rights. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 FIRST CAUSE OF ACTION 2 Fraud and Deceit 3 (Against Li and Pinscreen) 4 155. Sadeghi incorporates by this reference the allegations contained in each paragraph 5 above as if fully set forth here. 6 156. Sadeghi alleges that Li, on behalf of Pinscreen, willfully deceived Sadeghi with the 7 intent to induce Sadeghi to alter his employment at Google and to join Pinscreen. 8 157. Li, on behalf of Pinscreen, intentionally misrepresented Pinscreen’s technical 9 capabilities to Sadeghi and concealed its various illegal practices from him, which subsequently 10 caused Sadeghi harm. 11 158. Sadeghi alleges, on information and belief, that Li intended for Sadeghi to rely on 12 his misrepresentations, resign from Google, and join Pinscreen, in order to gain access to Sadeghi’s 13 expertise and experience in digital hair appearance and software engineering. 14 159. Reasonably relying on Li’s misrepresentations, Sadeghi resigned from Google and 15 joined Pinscreen. 16 160. A strong justification for Sadeghi’s reasonable reliance on Li’s misrepresentations is 17 that Li, on information and belief, was and is an assistant professor at USC. Li’s claims to have 18 automated that which he had merely fabricated means that Li has committed academic misconduct 19 which, if discovered, could be subject to draconian punishment. 20 161. Crucial to Sadeghi’s decision to sign the contract with Pinscreen and to resign from 21 Google was Li’s intentional misrepresentation of Pinscreen’s technical capabilities, including Li’s 22 claim on January 22, 2017, that Pinscreen was capable of automatically generating the avatars that 23 Li presented to Sadeghi on that same day. 24 162. On January 22, 2017, at 3:39 p.m., Li sent Sadeghi in private written Facebook 25 messages, two sets of input images as well as their corresponding supposedly automatically 26 generated (“autogenerated”) output avatars. Sadeghi expressed his surprise and asked Li whether 27 the avatar’s hair was “autogenerated.” Li responded to Sadeghi in writing, “yes.” 28 163. [January 22, 2017, at 3:43 p.m.] Sadeghi: “[…] Autogenerated hair?” Li: “Yes” 30 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 164. Li’s claim that the presented avatars and their hair were automatically generated was 2 a brazen lie. Li and Pinscreen repeatedly misrepresented manually prepared avatars as automatic, 3 even up to six months after Li’s initial fraudulent representations to Sadeghi, including during 4 Pinscreen’s public demo at SIGGRAPH RTL 2017, on August 1, 2017. 5 165. Accurate copies of Li’s fraudulent misrepresentations to Sadeghi, are attached in 6 Exhibit C and are incorporated here by reference. 7 166. Sadeghi would not have resigned from Google and joined Pinscreen if Li did not 8 intentionally conceal that Pinscreen and Li were involved in data fabrication, academic misconduct, 9 and other unlawful practices. 10 167. Sadeghi alleges, on information and belief, that Li’s misrepresentation and 11 concealment were intentional. On information and belief, Li was aware that his representation to 12 Sadeghi was false when he made it and also that he is concealing Pinscreen’s data fabrication and 13 academic misconduct from Sadeghi. 14 168. These fraudulent misrepresentations were made by Li both individually, as a major 15 shareholder of Pinscreen, and on behalf of Pinscreen, as its co-founder and Chief Executive Officer 16 (“CEO”). 17 169. Sadeghi was damaged, in an amount to be determined at trial, by being fraudulently 18 induced to give up his employment at Google which income and benefits were unsubstituted once 19 Sadeghi was retaliated against and wrongfully terminated from Pinscreen. 20 170. As a direct, foreseeable and proximate result of Pinscreen, through Li, willfully 21 deceiving Sadeghi to resign from Google and join Pinscreen, Sadeghi has lost and will continue to 22 lose income and benefits and has suffered and continues to suffer mental and emotional distress, all 23 to Sadeghi’s damage, in an amount to be determined at trial. 24 171. Sadeghi is entitled to punitive or exemplary damages because brazen deceit is 25 malicious. 26 27 28 31 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 SECOND CAUSE OF ACTION 2 Assault and Battery 3 (Against Li, Pinscreen and Does 1 through 100)

4 172. Sadeghi incorporates by this reference the allegations contained in each paragraph 5 above as if fully set forth here. 6 173. Sadeghi alleges that the defendants, including Li, committed battery on him through 7 intentional, nonconsensual, offensive and harmful physical contact. 8 174. On August 7, 2017, four of Pinscreen employees, including Li, violently grabbed and 9 restrained Sadeghi and physically attacked him. They forcefully opened Sadeghi’s backpack and 10 took possession of his work laptop. 11 175. The physical altercation is captured on the security cameras of Pinscreen’s office’s 12 building and is described by the security officers on duty as Sadeghi being “grabbed,” “brought to 13 the ground,” and “taken to the ground” by Pinscreen employees. 14 176. Sadeghi did not consent to being touched, grabbed, and restrained by the defendants. 15 177. Sadeghi was offended, harmed and physically injured by defendants’ battery, 16 required medical attention and continues to seek physical therapy. Besides physical pain and 17 suffering, Sadeghi has suffered substantial physical, mental and emotional distress as a result of the 18 battery, and the consequent physical injury. 19 178. A reasonable person in Sadeghi’s situation would have been offended by the 20 unconsented physical contact and battery. 21 179. Sadeghi requests for attorney’s fees and expenses pursuant to California Penal Code 22 § 1202.4. 23 THIRD CAUSE OF ACTION 24 Violation of California Labor Code § 1102.5 – Retaliation Against Whistleblowing 25 (Against Pinscreen) 26 180. Sadeghi incorporates by this reference the allegations contained in each paragraph 27 above as if fully set forth here. 28 181. California Labor Code § 1102.5 (b), in pertinent part, provides: “An employer, or 32 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 any person acting on behalf of the employer, shall not retaliate against an employee for disclosing 2 information, or because the employer believes that the employee disclosed or may disclose 3 information, to a government or law enforcement agency, to a person with authority over the 4 employee or another employee who has the authority to investigate, discover, or correct the violation 5 […], if the employee has reasonable cause to believe that the information discloses a violation of 6 state or federal statute, or a violation of or noncompliance with a local, state, or federal rule or 7 regulation, regardless of whether disclosing the information is part of the employee’s job duties.” 8 182. Sadeghi alleges, on information and belief, that Li, on behalf of Pinscreen, 9 wrongfully terminated him in retaliation for his objections to Li’s and Pinscreen’s illegal practices. 10 183. Sadeghi entered into an employment contract with Pinscreen, on January 23, 2017. 11 An accurate copy of the employment contract, which is signed by Li and Sadeghi, is attached as 12 Exhibit G and is incorporated here by reference. 13 184. Sadeghi alleges, on information and belief, that Li and Pinscreen believed that 14 Sadeghi might disclose their illegal practices to a government agency or law enforcement agency. 15 185. Li and Pinscreen knew that Sadeghi had objected to their illegal practices to Li, who 16 had authority over Sadeghi and to investigate, discover, and correct the misconduct. 17 186. Pinscreen’s and Li’s illegal practices included data fabrication, academic misconduct 18 and refusal to pay overtime compensation. Sadeghi opposed these wrongful activities and had 19 reasonable cause to believe that Li’s data fabrication and academic misconduct constituted 20 “investment fraud” and that Li’s refusal to pay overtime compensation was in violation of California

21 labor laws, including California Labor Code § 510. 22 187. Therefore, Sadeghi’s objections to Li’s and Pinscreen’s illegal practices were 23 protected whistleblowing activities. 24 188. Li, on behalf of Pinscreen, terminated Sadeghi on August 7, 2017. 25 189. Sadeghi alleges, on information and belief, that Sadeghi’s protected act of objecting 26 to Li’s and Pinscreen’s illegal practices to Li was a contributing factor in Li’s decision to terminate 27 Sadeghi. 28 190. As a direct, foreseeable and proximate result of Pinscreen, through Li, wrongfully 33 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 terminating Sadeghi in retaliation of Sadeghi’s objections to Li regarding defendants’ illegal 2 practices, Sadeghi has lost and will continue to lose income and benefits and has suffered and 3 continues to suffer severe physical, mental and emotional distress, all to Sadeghi’s damage, in an 4 amount to be determined at trial. 5 191. On information and belief, Li’s retaliation against Sadeghi, on behalf of Pinscreen, 6 was in a deliberate, cold, callous, malicious, oppressive and intentional manner in order to injure 7 and damage Sadeghi. Therefore, Sadeghi is entitled to punitive and exemplary damages against Li 8 and Pinscreen in an amount appropriate to punish to be determined at trial. 9 192. Because this claim arising under California state law is a matter of public concern, 10 and affects the public at large, Sadeghi requests for attorney’s fees and expenses pursuant to 11 California Code of Civil Procedure § 1021.5. 12 FOURTH CAUSE OF ACTION 13 Breach of Contract 14 (Against Pinscreen) 15 193. Sadeghi incorporates by this reference the allegations contained in each paragraph 16 above as if fully set forth here. 17 194. Sadeghi alleges that Pinscreen breached his employment contract which caused him 18 harm. 19 195. Sadeghi entered into an employment contract with Pinscreen, on January 23, 2017. 20 An accurate copy of the employment contract, which is signed by Li and Sadeghi, is attached as 21 Exhibit G and is incorporated here by reference. 22 196. Sadeghi substantially performed all of his duties under the contract. 23 197. Pinscreen materially breached Sadeghi’s employment contract by asking Sadeghi to 24 participate in the preparation and presentation of fabricated results in the SIGGRAPH 2017 RTL 25 public demo as well as other unlawful misrepresentations. 26 198. Pinscreen, materially breached Sadeghi’s employment by retaliating against 27 Sadeghi, and by terminating Sadeghi after he raised concerns over Pinscreen’s data fabrication, labor 28 law violations, and other unlawful practices. 34 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 199. Pinscreen materially breached Sadeghi’s employment contract by failing to 2 reimburse Sadeghi for his business-related expenses. 3 200. Li, on behalf of Pinscreen, terminated Sadeghi on August 7, 2017. 4 201. Sadeghi was terminated after being employed at Pinscreen for just over six months, 5 shortly after Pinscreen gained access to Sadeghi’s expertise in software engineering and digital hair 6 appearance modeling as well as Sadeghi’s implementation of a variation of his published and 7 patented hair rendering framework. The termination happened within Sadeghi’s first working hour 8 after Pinscreen’s fabricated presentation at SIGGRAPH 2017 RTL, and during the meeting that 9 Sadeghi had requested to address his concerns regarding Pinscreen’s illegal and unethical practices. 10 202. Sadeghi was damaged by the breach of contract, and as a result of his unlawful 11 termination from Pinscreen, in an amount equal to his reasonable expectations, should he have been 12 ethically and legally able to remain in the company, to be determined at trial. 13 FIFTH CAUSE OF ACTION 14 Breach of Implied Contract 15 (Against Pinscreen) 16 203. Sadeghi incorporates by this reference the allegations contained in each paragraph 17 above as if fully set forth here. 18 204. Sadeghi alleges that Pinscreen breached the implied contract between him and the 19 company which caused him harm. 20 205. Sadeghi entered into an employment contract with Pinscreen, on January 23, 2017. 21 An accurate copy of the employment contract, which is signed by Li and Sadeghi, is attached as 22 Exhibit G and is incorporated here by reference. 23 206. Sadeghi substantially performed all of his duties under the contract. 24 207. Pinscreen had an implied-in-fact agreement and obligation to comply with the law, 25 conform with scientific research ethics, and to follow academic conduct guidelines. 26 208. Pinscreen breached this implied contract by engaging, and by asking Sadeghi to 27 participate, in its data fabrication, academic misconduct and other unlawful practices. 28 209. Sadeghi was damaged, through loss of intellectual property, by having to request the 35 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 SIGGRAPH community to retract his name from the authorship of Pinscreen’s fabricated 2 publications, despite his authentic and significant contributions, for example, to Pinscreen’s digital 3 hair appearance. 4 SIXTH CAUSE OF ACTION 5 Breach of Implied Covenant of Good Faith and Fair Dealing 6 (Against Pinscreen) 7 210. Sadeghi incorporates by this reference the allegations contained in each paragraph

8 above as if fully set forth here. 9 211. In every contract, express or implied-in-fact, there is an implied promise of good 10 faith and fair dealing. This means that each party shall not do anything to unfairly interfere with the 11 right of any other party to receive the benefits of the contract. 12 212. Sadeghi alleges that Pinscreen violated the duty to act fairly and in good faith which 13 caused him harm. 14 213. Sadeghi entered into an employment contract with Pinscreen, on January 23, 2017. 15 An accurate copy of the employment contract, which is signed by Li and Sadeghi, is attached as 16 Exhibit G and is incorporated here by reference. 17 214. Sadeghi substantially performed all of his duties under the contract. 18 215. All conditions required for Pinscreen’s performance of the contract were met. 19 216. Pinscreen, through Li, acted unfairly and in bad faith when it interfered with 20 Sadeghi’s right to receive the benefits of the contract by retaliating against Sadeghi, and by 21 terminating Sadeghi after he raised concerns over Li’s and Pinscreen’s data fabrication, labor law 22 violations, and other unlawful practices. 23 217. Li, on behalf of Pinscreen, terminated Sadeghi on August 7, 2017. 24 218. Sadeghi was damaged by the breach of implied covenant of good faith and fair 25 dealing, and as a result of his unlawful termination from Pinscreen, in an amount equal to his 26 reasonable expectations, should he have been ethically and legally able to remain in the company, 27 to be determined at trial. 28 36 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 SEVENTH CAUSE OF ACTION 2 Wrongful Termination in Violation of California’s Public Policy 3 (Against Pinscreen) 4 219. Sadeghi incorporates by this reference the allegations contained in each paragraph 5 above as if fully set forth here. 6 220. Sadeghi alleges that he was terminated from Pinscreen for reasons that violate 7 California’s public policy. It is a violation of public policy of California to terminate an employee 8 for objecting to employer’s illegal, unethical, and wrongful practices. 9 221. Sadeghi entered into an employment contract with Pinscreen, on January 23, 2017. 10 An accurate copy of the employment contract, which is signed by Li and Sadeghi, is attached as 11 Exhibit G and is incorporated here by reference. 12 222. Li, on behalf of Pinscreen, terminated Sadeghi on August 7, 2017. 13 223. Sadeghi alleges, on information and belief, that his objections to Li’s and Pinscreen’s 14 illegal practices was a substantial motivating reason for Sadeghi’s termination 15 224. Among those deceived by Li’s intentional misrepresentations of Pinscreen’s 16 technical capabilities were Pinscreen investors. 17 225. California’s public policy against Li’s and Pinscreen’s data fabrication is expressed 18 in the laws prohibiting deceit of investors and imposing a fiduciary duty of corporate officers toward 19 investors. 20 226. California’s public policy against Li’s and Pinscreen’s labor law violations is 21 expressed in California labor laws mandating overtime payments for nonexempt employees, 22 specifically California Labor Code § 510. 23 227. These public policies are fundamental, substantial, well established and involve 24 matters that affect society at large. 25 228. Sadeghi is informed and believes, and on that basis alleges, that the termination of 26 his employment by Pinscreen was in retaliation for Sadeghi’s objections to Li’s and Pinscreen’s 27 illegal practices, including data fabrications and labor law violations, and was, therefore, carried out 28 in violation of California’s public policy. 37 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 229. As a direct, foreseeable and proximate result of Pinscreen wrongfully terminating 2 Sadeghi in violation of California’s public policy, Sadeghi has lost and will continue to lose income 3 and benefits and has suffered and continues to suffer severe physical, mental and emotional distress, 4 all to Sadeghi’s damage, in an amount to be determined at trial. 5 230. Li’s wrongful termination of Sadeghi, on behalf of Pinscreen was, on information 6 and belief, in a deliberate, cold, callous, malicious, oppressive and intentional manner in order to 7 injure and damage Sadeghi. Therefore, Sadeghi is entitled to punitive and exemplary damages 8 against Li and Pinscreen in an amount appropriate to punish to be determined at trial and make an 9 example of those defendants. 10 231. Because this claim arising under California state law is a matter of public concern, 11 and affects the public at large, Sadeghi requests for attorney’s fees and expenses pursuant to 12 California Code of Civil Procedure § 1021.5. 13 EIGHTH CAUSE OF ACTION 14 Intentional Interference with Contract 15 (Against Li and Pinscreen)

16 232. Sadeghi incorporates by this reference the allegations contained in each paragraph 17 above as if fully set forth here. 18 233. Sadeghi alleges, on information and belief, that Li, on behalf of Pinscreen, without 19 privilege or justification, intentionally interfered with Sadeghi’s employment contract with Google. 20 234. Sadeghi alleges, on information and belief, that Li, solely based on personal motives 21 unrelated to his agency for Pinscreen, without privilege or justification, intentionally interfered with 22 Sadeghi’s employment contract with Pinscreen. 23 235. Sadeghi was in an employment contract with Google, starting August 15, 2011, until 24 February 1, 2017 when he resigned from Google in order to join Pinscreen on February 2, 2017. 25 236. Sadeghi entered into an employment contract with Pinscreen, on January 23, 2017. 26 An accurate copy of the employment contract, which is signed by Li and Sadeghi, is attached as 27 Exhibit G and is incorporated here by reference. 28 237. Sadeghi alleges, on information and belief, that Li was aware of the existence of 38 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s employment contract with Google and later with Pinscreen. 2 238. Sadeghi alleges, on information and belief, that Li, on behalf of Pinscreen, 3 intentionally interfered with and disrupted the performance of Sadeghi’s employment contract with 4 Google in order to gain access to Sadeghi’s expertise and experience in digital hair appearance and 5 software engineering as well as an implementation of Sadeghi’s hair rendering framework, by 6 defrauding Sadeghi through intentional misrepresentations and concealments. 7 239. Sadeghi alleges, on information and belief, that Li intended to induce a breach of 8 Sadeghi’s employment contract with Pinscreen by illegally retaliating against Sadeghi and 9 wrongfully terminating him. 10 240. Sadeghi alleges, on information and belief, that Li’s retaliation and wrongful 11 termination of Sadeghi from Pinscreen, was engineered by Li for personal motives unrelated to his 12 agency for Pinscreen as its CEO. 13 241. Sadeghi alleges, on information and belief, that Li interfered with and disrupted the 14 performance of Sadeghi’s employment contract with Pinscreen because he feared Sadeghi would 15 expose his transgression of inviolate academic norms prohibiting the fabrication of data. 16 242. Sadeghi was damaged by Li’s interference with Sadeghi’s employment contracts 17 with Google and later with Pinscreen in amounts to be determined at trial. 18 243. As a direct, foreseeable and proximate result of Li’s interference with Sadeghi’s 19 employment contracts with Google and Pinscreen, Sadeghi has lost and will continue to lose income 20 and benefits and has suffered and continues to suffer severe physical, mental and emotional distress, 21 all to Sadeghi’s damage, in an amount to be determined at trial. 22 244. On information and belief, Li’s interference with Sadeghi’s contracts, partially on 23 behalf of Pinscreen, were in a deliberate, cold, callous, malicious, oppressive and intentional manner 24 in order to injure and damage Sadeghi. Therefore, Sadeghi is entitled to punitive and exemplary 25 damages against Li and Pinscreen in an amount appropriate to punish to be determined at trial. 26 27 28 39 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 NINTH CAUSE OF ACTION 2 Negligent Hiring, Supervision or Retention 3 (Against Pinscreen and Does 1 through 100)

4 245. Sadeghi incorporates by this reference the allegations contained in each paragraph 5 above as if fully set forth here. 6 246. Sadeghi alleges that he was harmed and that Pinscreen is liable for it because 7 Pinscreen negligently hired and retained an unfit and incompetent CEO, did not properly train him, 8 and did not properly supervise him. 9 247. Li was unfit and incompetent to perform the duties required for the CEO role at 10 Pinscreen due to numerous instances of fraud, data fabrication, academic misconduct, disregard for 11 California labor laws and other illegal practices. Li’s actions have been reckless, vicious and have 12 caused harm to Pinscreen employees, including Sadeghi, and other Pinscreen stakeholders, 13 including its investors. 14 248. On information and belief, Li was ineligible to work at Pinscreen as its CEO and has 15 performed work for the company illegally because Li is not a US Citizen, his permanent residency 16 (i.e. green card) application has been rejected, and he lacks a proper visa to work at Pinscreen. On 17 information and belief, Li has an H-1B visa sponsored by USC, which only allows him to work at 18 the university and not at Pinscreen. In response to Sadeghi’s inquiry about Li’s work authorization 19 and eligibility, Li claimed that he does not need a visa to work for Pinscreen since he is not receiving 20 any salary from the company. However, on information and belief, Li’s working at Pinscreen 21 without a proper visa was and is in violation of the Immigration Reform and Control Act of 1986. 22 249. Pinscreen knew, should have known, or had failed to use reasonable care to discover, 23 that Li was unfit, incompetent, and ineligible to work for the company. 24 250. Pinscreen knew, or should have known, that Li’s unfitness, incompetence, and 25 ineligibility created a particular risk to its employees, including Sadeghi, its investors and the public. 26 251. Li’s unfitness, incompetence, and ineligibility harmed Sadeghi by, including but not 27 limited to, being fraudulently deceived, illegally retaliated against, wrongfully terminated, and 28 unlawfully battered, in the amount to be determined at trial. 40 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 252. As a direct, foreseeable and proximate result of Li’s unfitness, incompetence, and 2 ineligibility, Sadeghi has lost and will continue to lose income and benefits and has suffered and 3 continues to suffer severe physical, mental and emotional distress, all to Sadeghi’s damage, in an 4 amount to be determined at trial. 5 253. Pinscreen’s negligence in hiring, training, supervision, and retention of Li was a 6 substantial factor in causing Sadeghi’s harm. 7 TENTH CAUSE OF ACTION 8 False Imprisonment 9 (Against Li, Pinscreen, and Does 1-100)

10 254. Sadeghi incorporates by this reference the allegations contained in each paragraph 11 above as if fully set forth here. 12 255. Sadeghi alleges that Li committed false imprisonment on Sadeghi by intentionally 13 confining him, without consent, without lawful privilege, for an appreciable length of time, causing 14 Sadeghi to suffer harm. 15 256. As set forth above, on August 7, 2017, concerned by Li’s aggressive behavior, 16 Sadeghi decided to leave Pinscreen’s office, however, Li physically blocked the door of the office, 17 forcefully restricted Sadeghi’s freedom of movement, and intentionally confined Sadeghi inside 18 Pinscreen’s office against Sadeghi’s consent. 19 257. As a direct, foreseeable and proximate result of Li falsely imprisoning Sadeghi, 20 Sadeghi has suffered and continues to suffer severe mental and emotional distress, all to Sadeghi’s 21 damage, in an amount to be determined at trial. 22 258. On information and belief, Li’s false imprisonment of Sadeghi, on behalf of 23 Pinscreen, was in a deliberate, cold, callous, malicious, oppressive and intentional manner in order 24 to injure and damage Sadeghi. Therefore, Sadeghi is entitled to punitive and exemplary damages 25 against Li and Pinscreen in an amount appropriate to punish to be determined at trial and make an 26 example of those defendants. 27 259. Sadeghi requests for attorney’s fees and costs in amount to be proven at trial. 28 41 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 ELEVENTH CAUSE OF ACTION 2 Invasion of Privacy 3 (Against Li, Pinscreen, and Does 1 through 100)

4 260. Sadeghi incorporates by this reference the allegations contained in each paragraph 5 above as if fully set forth here. 6 261. Sadeghi alleges that Li, Pinscreen and other defendants violated his right to privacy 7 in a manner that is highly offensive to a reasonable person. 8 262. Sadeghi had a reasonable expectation of privacy in the contents of his backpack, and 9 the personal files stored on his work laptop into which Pinscreen intentionally intruded. 10 263. On August 7, 2017, while committing battery on Sadeghi, the defendants 11 intentionally intruded Sadeghi’s backpack and took his work laptop by force. The defendants are 12 unlawfully in possession of Sadeghi’s private files, including only copies of Sadeghi’s personal 13 anniversary trip photos and videos containing explicit photos of himself. 14 264. Sadeghi’s demands for his personal files has been repeatedly ignored by Pinscreen. 15 Pinscreen’s refusal to return Sadeghi’s private data would be highly offensive to the reasonable 16 person and constitutes an invasion of privacy. 17 265. As a direct, foreseeable and proximate result of Pinscreen, Li and other defendants 18 invading Sadeghi’s privacy, Sadeghi has suffered and continues to suffer severe mental and 19 emotional distress, all to Sadeghi’s damage, in an amount to be determined at trial. 20 266. The invasion of Sadeghi’s privacy, carried out by Pinscreen, Li, and other defendants 21 was, on information and belief, in a deliberate, cold, callous, malicious, oppressive and intentional 22 manner in order to injure and damage Sadeghi. Therefore, Sadeghi is entitled to punitive and 23 exemplary damages against the defendants in an amount appropriate to punish to be determined at 24 trial and make an example of those defendants. 25 26 27 28 42 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 TWELFTH CAUSE OF ACTION 2 Conversion 3 (Against Li, Pinscreen, and Does 1 through 100)

4 267. Sadeghi incorporates by this reference the allegations contained in each paragraph 5 above as if fully set forth here. 6 268. Sadeghi alleges that Li, Pinscreen and other defendants, wrongfully exercised control 7 over Sadeghi’s personal property. 8 269. Sadeghi owned, possessed, and had a right to possess his personal files including the 9 photos and videos of his personal anniversary trip. 10 270. The defendants intentionally and substantially interfered with Sadeghi’s property by 11 forcefully taking possession of Sadeghi’s work laptop which contained his personal data, preventing 12 Sadeghi from having access to his data, and refusing to return Sadeghi’s personal property after 13 Sadeghi demanded its return. 14 271. Pinscreen has illegally refused to return Sadeghi’s personal data on his work laptop, 15 which contained some of the only copies of Sadeghi’s anniversary trip photos and videos, including 16 explicit photos of himself. These photos were taken immediately prior to Sadeghi’s work-related 17 travel to a conference in Hawaii and temporarily stored on the laptop. These private files do not 18 relate to Sadeghi’s employment at Pinscreen and are Sadeghi’s personal property. 19 272. On August 7, 2017, while committing battery on Sadeghi, the defendants forcefully 20 took possession of Sadeghi’s work laptop which contained his personal data. Li promised Sadeghi, 21 “we will give you your personal files”, however, Pinscreen has subsequently refused to do so. These 22 photos have sentimental value to Sadeghi, and Pinscreen has converted these files by illegally 23 retaining and refusing to return this property. 24 273. As a direct, foreseeable and proximate result of Pinscreen, illegally converting 25 Sadeghi’s personal files, Sadeghi has suffered and continues to suffer severe mental and emotional 26 distress, all to Sadeghi’s damage, in an amount to be determined at trial. 27 274. The conversion of Sadeghi’s properties, carried out by Pinscreen, Li, and other 28 defendants were, on information and belief, in a deliberate, cold, callous, malicious, oppressive and 43 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 intentional manner in order to injure and damage Sadeghi. Therefore, Sadeghi is entitled to punitive 2 and exemplary damages against the defendants in an amount appropriate to punish to be determined 3 at trial. 4 THIRTEENTH CAUSE OF ACTION 5 Negligence 6 (Against Li, Pinscreen, and Does 1 through 100)

7 275. Sadeghi incorporates by this reference the allegations contained in each paragraph 8 above as if fully set forth here. 9 276. Sadeghi alleges that he was harmed by Pinscreen’s, Li’s and other defendants’ 10 negligence which consequently caused damages to Sadeghi’s personal property. 11 277. As Sadeghi’s employer, Pinscreen owed Sadeghi a duty of due care. This duty of due 12 care included the duty to avoid damaging Sadeghi’s personal property at his desk. Pinscreen 13 breached the duty of due care by breaking Sadeghi’s hand-made sculpture, with sentimental value, 14 after Sadeghi was unlawfully terminated from Pinscreen. 15 278. As a direct, foreseeable and proximate result of the defendants’ negligence and 16 breach of duty of due care, Sadeghi’s personal property, and as a result Sadeghi was harmed and 17 has suffered and continues to suffer severe mental and emotional distress, all to Sadeghi’s damage, 18 in an amount which will be proven at trial. 19 FOURTEENTH CAUSE OF ACTION 20 Intentional Infliction of Emotional Distress 21 (Against Li, Pinscreen, and Does 1 through 100)

22 279. Sadeghi incorporates by this reference the allegations contained in each paragraph 23 above as if fully set forth here. 24 280. Sadeghi alleges that defendants’ actions have caused Sadeghi to suffer severe mental 25 and emotional distress due to, including but not limited to, being fraudulently deceived to leave his 26 employment at Google, being wrongfully terminated from his employment at Pinscreen, being 27 falsely imprisoned, being battered, being physically injured, invasion of his privacy, conversion of 28 his personal files and infringement of his intellectual property rights. 44 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 281. Pinscreen’s, Li’s and other defendants’ conduct was outrageous because the 2 defendants abused the employment relationship which had given them power to damage Sadeghi’s 3 interest, knew that Sadeghi was susceptible to injuries through mental and emotional distress, acted 4 intentionally and unreasonably with the recognition that their actions are likely to cause mental and 5 emotional distress. 6 282. Li and other defendants intended to cause Sadeghi mental and emotional distress or 7 acted with reckless disregard of the probability that Sadeghi would suffer mental and emotional 8 distress. 9 283. As a direct, foreseeable and proximate result of defendants’ unlawful actions, 10 Sadeghi has lost and will continue to lose income and benefits and has suffered and continues to 11 suffer severe mental and emotional distress, all to Sadeghi’s damage, in an amount to be determined 12 at trial. 13 284. On information and belief, the acts taken toward Sadeghi, carried out by the 14 defendants, including Li, on behalf of Pinscreen, were in a deliberate, cold, callous, malicious, 15 oppressive and intentional manner in order to injure and damage Sadeghi. Therefore, Sadeghi is 16 entitled to punitive and exemplary damages against the defendants in an amount appropriate to 17 punish to be determined at trial. 18 FIFTEENTH CAUSE OF ACTION 19 Violation of California Labor Code § 2802

20 (Against Li, Pinscreen and Does 1 through 100) 21 285. Sadeghi incorporates by this reference the allegations contained in each paragraph 22 above as if fully set forth here. 23 286. California Labor Code § 2802, in pertinent part, provides: “(a) An employer shall 24 indemnify his or her employee for all necessary expenditures or losses incurred by the employee in 25 direct consequence of the discharge of his or her duties. […] (c) For purposes of this section, the 26 term necessary expenditures or losses shall include all reasonable costs, including, but not limited 27 to, attorney s fees incurred by the employee enforcing the rights granted by this section. (d) In 28 addition to recovery of penalties under this section in a court action or proceedings pursuant to 45 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Section 98, the commissioner may issue a citation against an employer or other person acting on 2 behalf of the employer who violates reimbursement obligations for an amount determined to be due 3 to an employee under this section.” 4 287. After Sadeghi’s wrongful termination, Pinscreen withheld business expense 5 reimbursements despite prior written agreements, in violation of Sadeghi’s employment contract. 6 288. Pinscreen acknowledged that the reimbursements were due but claimed that it would 7 only pay them pending a successful settlement and/or mutual non-disclosure agreement. After more 8 than nine months delay, Pinscreen paid only a small portion of the past due reimbursements, in 9 violation of Sadeghi’s contract and prior written agreements. 10 289. As a direct, foreseeable and proximate result of Pinscreen refusing to reimburse 11 Sadeghi for his business expenses, Sadeghi has lost and will continue to lose monetary benefits and 12 has suffered and continues to suffer mental and emotional distress, all to Sadeghi’s damage, in an 13 amount to be determined at trial. 14 290. On information and belief, the acts taken toward Sadeghi, carried out by the 15 defendants, including Li, on behalf of Pinscreen, were in a deliberate, cold, callous, malicious, 16 oppressive and intentional manner in order to injure and damage Sadeghi. Therefore, Sadeghi is 17 entitled to punitive and exemplary damages against the defendants in an amount appropriate to 18 punish to be determined at trial. 19 291. Sadeghi is entitled to recover attorney’s fees incurred in order to enforce these due 20 reimbursement payments. enforcing the rights granted by California Labor Code § 2802. 21 SIXTEENTH CAUSE OF ACTION 22 Violation of California Unfair Competition Law (UCL), 23 Business and Professions Code § 17200 et seq. 24 (Against Li, Pinscreen, and Does 1 through 100) 25 292. Sadeghi incorporates by this reference the allegations contained in each paragraph 26 above as if fully set forth here. 27 293. California Business & Professional Code § 17200 et seq. prohibits any “unlawful, 28 unfair, or fraudulent business act or practice” and any “unfair, deceptive, untrue or misleading 46 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 advertising.” 2 294. Li’s and Pinscreen’s data fabrication practices, as well as their other illegal conducts 3 were fraudulent, deceptive, misleading, unfair, unlawful and in violation of California Business & 4 Professional Code § 17200. 5 295. On information and belief, Li’s and Pinscreen’s fraudulent misrepresentations have 6 caused deception of the public, scientific community, and Pinscreen’s actual and potential investors. 7 296. Because Li’s and Pinscreen’s data fabrication, academic misconduct and other illegal 8 practices are ongoing, and there is no indication that they will cease their unlawful conduct, Sadeghi 9 request the court to enjoin Li and Pinscreen from further violations of the law. 10 297. Sadeghi is entitled to recover attorney’s fees and costs to be determined at trial. 11 SEVENTEENTH CAUSE OF ACTION 12 Declaratory Relief 13 (Against Li, Pinscreen, and Does 1 through 100) 14 298. Sadeghi incorporates by this reference the allegations contained in each paragraph 15 above as if fully set forth here. 16 299. Sadeghi desires a declaration of rights and other relief available pursuant to the 17 California Declaratory Judgment Act, C.C.P. §1060 et seq. 18 300. A declaratory judgment is necessary and proper in that Sadeghi contends that Li, 19 Pinscreen and other defendants have committed and continue to commit the violations set forth 20 above and, on information and belief, Li, Pinscreen and other defendants will deny that they have 21 done so and/or will continue to commit such acts. 22 23 24 25 26 27 28 47 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 PRAYER FOR RELIEF 2 WHEREFORE, Sadeghi respectfully requests for relief and judgment against Li, Pinscreen 3 and other defendants, jointly and severally, as follows, in amounts according to proof:

4 1. For judgment in favor of Sadeghi against Pinscreen, Li, and other defendants; 5 2. For declaratory relief; 6 3. For general, special and compensatory, punitive and exemplary damages; 7 4. For all applicable statutory penalties; 8 5. For pre- and post-judgment interest where allowed; 9 6. For attorneys’ fees under applicable provisions of law, including but not limited to California 10 Code of Civil Procedure § 1021.5, California Labor Code § 1102.5, and California Penal 11 Code § 1202.4;

12 7. For costs of suit incurred herein; and 13 8. For such other and further relief as the Court deems necessary, just and proper. 14 15 16 17 DATED: June 11, 2018 Respectfully submitted,

18 FERNALD LAW GROUP APC Brandon C. Fernald 19 Adam P. Zaffos

20

21

22

23

24 By: ______25 Adam P. Zaffos Attorneys for Plaintiff Dr. Iman Sadeghi 26 27 28 48 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 DEMAND FOR JURY TRIAL 2 Sadeghi hereby demands a jury trial on all claims and issues raised in Complaint for which 3 Sadeghi is entitled to a jury.

4 5 6 7 8 DATED: June 11, 2018 Respectfully submitted,

9 FERNALD LAW GROUP APC Brandon C. Fernald 10 Adam P. Zaffos

11 12 13 14

15 By: ______Adam P. Zaffos 16 Attorneys for Plaintiff Dr. Iman Sadeghi 17

18 19 20 21 22 23 24 25 26 27 28 49 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 VERIFICATION I, Dr. Iman Sadeghi, declare and verify as follows: 3 I am the plaintiff in this proceeding and have read this Complaint and know the contents 4 thereof. The information contained herein is accurate to the best of my knowledge except as to those 5 matters which are stated on information and belief, and as to those matters I believe them to be true. 6 I declare and verify under penalty of perjury under the laws of the State of California that 7 the foregoing is true and correct to my personal knowledge. 8

9

10

11

12 DATED: June 11, 2018 Respectfully submitted, 13 14 15 16 17 18 By: ______19 Dr. Iman Sadeghi

20 21 22 23 24 25 26 27 28 50 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT A 2 Sadeghi’s Qualifications 3 Sadeghi’s rendering titled “A Butterfly, a Water Drop and a High Speed Camera!” which 4 received the Grand Prize in UCSD’s Rendering Competition 2007:

5 • http://sadeghi.com/a-butterfly-a-water-drop-and-a-high-speed-camera 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

21

22 23 24 25 26 27 28 51 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Poster of UCSD’s Rendering Competition 2007 featuring the renderings for the Grand Prize, 2 First Prize, and honorable mentions: 3 4 5 6 7 8 9 10 11 12 13 14 15 16

17 18 19 20 21 22 23 24 25 26 27 28 52 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s “An Artist Friendly Hair Shading System” publication, in collaboration with Walt 2 Disney Animation Studios, which Sadeghi presented at SIGGRAPH 2010:

3 • http://sadeghi.com/an-artist-friendly-hair-shading-system 4 Publication page on Disney Research website:

5 • http://www.disneyresearch.com/publication/an-artist-friendly-hair-shading-system 6 7 8 9

10

11 Publication page on ACM Digital Library: 12 • http://dl.acm.org/citation.cfm?id=1778793 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

28 53 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s “System and Method for Artist Friendly Controls for Hair Shading” patent, in 2 collaboration with Walt Disney Animation Studios:

3 • http://www.google.com/patents/US8674988 4

5 Sadeghi’s movie credit for “Hair Rendering Development,” in Walt Disney Animation 6 Studios’ movie Tangled, on Internet Movie Database (“IMDb”):

7 • http://www.imdb.com/name/nm4205348 8

9 Li’s group messages to Sadeghi and freelance artist Leszek, on Skype, on April 18, 2017:

10 • [April 18, 2017] Li: “Hey Leszek”

11 • [April 18, 2017] Li: “Please meet Iman [Sadeghi], the guy behind all the hair 12 rendering [technology] for Disney and DreamWorks ([including] Tangled)” 13 14 15 16 17 18 19 20

21 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 22 other participants, on June 1, 2017: 23 • [June 1, 2017] [a Pinscreen employee]: “2 months is very tight lol for what needs to 24 happen” 25 • [June 1, 2017] Li: “No 2 months is good” 26 • [June 1, 2017] Li: “[an Academy Scientific and Technical (Sci-Tech) Award winner] 27 pulled his shit off in 1 month” 28 54 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [June 1, 2017] Li: “We have the best hair rendering guy” 2 3 4 5 6 7 8 9 10 11

12

13 In 2010, Li requested to be connected with Sadeghi on Facebook and LinkedIn: 14 • [July 29, 2010] “Hi Iman [Sadeghi], Hao Li wants to be friends with you on 15 Facebook.” 16 • [September 24, 2010] “Hao Li has indicated you [Sadeghi] are a friend: I’d like to add 17 you to my professional network on LinkedIn. - Hao Li” 18 19 20 21 22 23 24 25 26 27

28 55 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12

13 Li’s private conversation with Sadeghi, on Skype, on July 28, 2017: 14 • [July 28, 2017] Li: “[…] You [Sadeghi] are a good friend […]” 15 • [July 28, 2017] Sadeghi: “[…] You [Li] are a great friend […]” 16 17 18 19 20 21 22 23 24 25 26 27 28

56 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s Ph.D. dissertation, titled “Controlling the Appearance of Specular 2 Microstructures,” which Sadeghi defended on June 1, 2011: 3 • http://sadeghi.com/controlling-the-appearance-of-specular-microstructures 4 Doctoral dissertation page on ACM Digital Library: 5 • http://dl.acm.org/citation.cfm?id=2231594 6 7 8 9 10 11

12

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 57 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s “Physically-based Simulation of Rainbows” publication, a collaboration between 2 UCSD, Universidad de Zaragoza, and Disney Research, which Sadeghi presented at

3 SIGGRAPH 2012:

4 • http://sadeghi.com/physically-based-simulation-of-rainbows 5 Publication page on ACM Digital Library:

6 • http://dl.acm.org/citation.cfm?id=2077344

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

23 24 25 26 27 28 58 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s “A Practical Microcylinder Appearance Model for Cloth Rendering” 2 publication, a collaboration within UCSD, which Sadeghi presented at SIGGRAPH 2013:

3 • http://sadeghi.com/a-practical-microcylinder-appearance-model-for-cloth-rendering 4 Publication page on ACM Digital Library:

5 • http://dl.acm.org/citation.cfm?id=2451240 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

21 22 23 24 25 26 27 28 59 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT B 2 Li’s and Pinscreen’s Solicitation of Sadeghi 3 Li’s private conversation with Sadeghi, on Facebook, on November 8, 2016:

4 • [November 8, 2016] Li: “Ahahaha”

5 • [November 8, 2016] Li: “Join us!” 6 • [November 8, 2016] Sadeghi: “I know! I am seriously considering it. I want to see your

7 office 🙂🙂” 8 • [November 8, 2016] Li: “Yes yes” 9 • [November 8, 2016] Li: “Just now some folks at Adobe are asking” 10 • [November 8, 2016] Li: “They love the Trump shit”

11 • [November 8, 2016] Li: “This morning our company got valued at 30M” 12 • [November 8, 2016] Li: “More VCs knocking at our doors” 13 • [November 8, 2016] Li: “We [increased] [our] valuation by X8 since 3 months” 14 15 16 17 18 19 20 21

22 Li’s private messages to Sadeghi, on Facebook, on November 16, 2016: 23 • [November 16, 2016] Li: “OMG” 24 • [November 16, 2016] Li: “It will be awesome” 25 • [November 16, 2016] Li: “Join Pinscreen” 26 • [November 16, 2016] Li: “It will be fun” 27

28 60 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3

4 Li’s private conversation with Sadeghi, on Facebook, on November 18, 2016: 5 • [November 18, 2016] Sadeghi: “Good morning. I had a great time visiting you guys! 6 Really cool stuff. I just messaged [Pinscreen’s CTO] too. Let’s talk about the next 7 steps 🙂🙂” 8 • [November 18, 2016] Li: “Sounds good we’ll discuss with board and VCs [Venture 9 Capitalists] first. We are thinking about offering a VP position.” 10 11 12

13

14 Li’s private message to Sadeghi, on Facebook, on November 29, 2016:

15 • [November 29, 2016] Li: “We [thought] a lot about having you on board!” 16

17 Li’s private messages to Sadeghi, on Facebook, on November 30, 2016: 18 • [November 30, 2016] Li: “So for startup at our stage the biggest benefit is in stock 19 options” 20 • [November 30, 2016] Li: “Which value will significantly increase in the next round of 21 funding” 22 23 24

25 Li’s private conversation with Sadeghi, on Facebook, on December 1, 2016: 26 • [December 1, 2016] Li: “[Pinscreen’s CTO] thinks that [you] are awesome” 27 • [December 1, 2016] Sadeghi: “Oh cool! I really like him too. I wish I have had met 28 him at ILM [Industrial Light & Magic] 😃😃” 61 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2

3

4 Li’s private messages to Sadeghi, on Facebook, on December 1, 2016:

5 • [December 1, 2016] Li: “I have a few meetings with investors too” 6 • [December 1, 2016] Li: “And will have some more later today with the board”

7 • [December 1, 2016] Li: “We all want you to join, we are working out on a good 8 offer” 9 10

11

12 Li’s private e-mail to Sadeghi, with Subject “Offer Pinscreen <> Iman [Sadeghi],” on 13 December 18, 2016:

14 • [December 18, 2016] Li: “Iman [Sadeghi],”

15 • [December 18, 2016] Li: “First of all, congratulations on your offer as VP of 16 Engineering of Pinscreen! We have been really impressed by you and are very 17 thrilled with the possibility of having you as part of our amazing and unique team.”

18 • [December 18, 2016] Li: “We have had great feedbacks [sic] from the team as well as 19 from [one of Pinscreen’s co-founders and board members]. I believe we can do

20 amazing work together and really disrupt the social media and VR [Virtual Reality] / 21 AR [Augmented Reality] industry, and build a successful company together.”

22 • [December 18, 2016] Li: “We have been working hard with our board and investors, in 23 making you a strong offer and hope that you join our journey, being part of the first 24 employees.”

25 • [December 18, 2016] Li: “Attached is our offer from Pinscreen and a confidential 26 information and invention assignment agreement. Our offer is higher than the median

27 compensation for non-founder VP of engineering in Silicon Valley. As we move to the 28 62 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 next rounds of fundings [sic] and growth, the value of the company is likely to 2 increase significantly, so you would be joining at a great time now.”

3 • [December 18, 2016] Li: “After you have had a chance to review let’s schedule a call 4 to answer any questions. Please keep the information confidential and feel free to reach 5 out at any time.”

6 • [December 18, 2016] Li: “Thank you!” 7 • [December 18, 2016] Li: “Cheers,” 8 • [December 18, 2016] Li: “Hao Li” 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

26 Li’s private messages to Sadeghi, on Facebook, on December 26, 2016: 27 • [December 26, 2016] Li: “However, I think if you join us, you would bring a lot of 28 63 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 energy with you”

2 • [December 26, 2016] Li: “I think we can increase a bit”

3 • [December 26, 2016] Li: “Do you think there is a chance you can start earlier?” 4 5 6

7 Li’s private conversation with Sadeghi, on Facebook, on December 26, 2016:

8 • [December 26, 2016] Sadeghi: “Hmmm … I understand the potential here. But with any 9 potential comes risk hand in hand.”

10 • [December 26, 2016] Sadeghi: “What do they say about the DFJ stats I sent you regarding 11 the 3% post Series A equity share?”

12 • [December 26, 2016] Sadeghi: “http://www.slideshare.net/markpeterdavis/vc-bootcamp- 13 by-dfj-gotham-ventures-and-wilson-sonsini-goodrick-rosati/65- 14 Typical_Option_Grants_ulliA_very”

15 • [December 26, 2016] Li: “It’s 1-3% 🙂🙂” 16 • [December 26, 2016] Li: “But it really depends on the company” 17 • [December 26, 2016] Li: “The one feedback I got a lot from investors is that they know 18 there is huge interest from other companies in partnering/acquiring, and the field is hot

19 right now, also we haven't shown you our latest update yet 🙂🙂”

20 • [December 26, 2016] Li: “Also I don’t think there are any risks 🙂🙂” 21 • [December 26, 2016] Li: “You will be a polar bear with an iron man suit” 22 23 24 25 26 27 28 64 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9

10 Li’s private conversation with Sadeghi, on Facebook, on December 26, 2016: 11 • [December 26, 2016] Li: “OMG” 12 • [December 26, 2016] Li: “♥” 13 • [December 26, 2016] Li: “Do you think you will be able to join us in January 14 already?” 15 • [December 26, 2016] Li: “We are aiming for a beta launch in late January” 16 • [December 26, 2016] Sadeghi: “Hmmm ... The yearly Google bonus is out Jan 20th.” 17 • [December 26, 2016] Li: “So [you] could start in [February]?” 18 • [December 26, 2016] Li: “That will be still before we launch a PR thing” 19 • [December 26, 2016] Li: “I can discuss again with the board, but I would like to offer 20 you for the polar bear heart: 165K + 2.3%” 21 • [December 26, 2016] Li: “Important thing to notice is that our valuation is already very 22 high for a company in this stage and it’s growing lately fast” 23 • [December 26, 2016] Li: “So current value is 30M especially since we have built all 24 the backend platform for user creation and a [technology] that is state of the art” 25 26 27 28 65 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11

12

13 Li’s private messages to Sadeghi, on Facebook, on December 26, 2017: 14 • [December 26, 2016] Li: “Join us!” 15 • [December 26, 2016] Li: “Pinscreen will grow, I’m sure, you are sure” 16 • [December 26, 2016] Li: “And you will be able to grow as well, I’m quite sure the 17 reward is bigger than [with] the other companies, not only in terms of impact but 18 also financially” 19 20 21

22 Li’s private conversation with Sadeghi, on Facebook, on December 26, 2016: 23 • [December 26, 2016] Sadeghi: “Regarding the offer: thanks for the salary bump. The 24 share % still doesn’t feel right to my heart. And I fully understand you have limited 25 resources.” 26 • [December 26, 2016] Li: “How can I hire you?” 27 • [December 26, 2016] […] 28 66 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [December 26, 2016] Li: “Tell me a number” 2 • [December 26, 2016] […]

3 • [December 26, 2016] Li: “[…] I still hope we can make something happen as I'm 4 really excited to get you here. Salaries will of course be increased based on the stage 5 the company will be, as well as bonus will be offered to reward for the work. […]”

6 • [December 26, 2016] […] 7 • [December 26, 2016] Sadeghi: “Share % is more important than the salary. Would it be 8 possible to have a clause to up my share post Series A to make up for the dilution?”

9 • [December 26, 2016] Li: “I can bring it up if you want in the meeting, but think it’s 10 better we agree on a number”

11 • [December 26, 2016] Li: “Let me know if you want me to proceed.” 12 • [December 26, 2016] […]

13 • [December 26, 2016] Li: “In the end trust your gut feeling and your heart.” 14 15

16 … 17

18 … 19 20

21 … 22 23 24

25 … 26

27 Li’s private message to Sadeghi, on Facebook, on December 26, 2016: 28 67 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [December 26, 2016] Li: “But I do believe that you will bring a lot to the company”

2 3 Li’s private messages to Sadeghi, on Facebook, on January 18, 2017: 4 • [January 18, 2017] Li: “There are also some updates about Pinscreen” 5 • [January 18, 2017] Li: “We have pushed significantly our [technology] since we 6 chatted last time, and some big investors are extremely interested in funding us” 7 • [January 18, 2017] Li: “There [sic] funds are significant and could raise the value of 8 the company significantly” 9 • [January 18, 2017] Li: “[one of Pinscreen’s VC partners from Lux Capital] was 10 also very excited of having you join us” 11 • [January 18, 2017] Li: “I think he likes you a lot” 12 13 14

15 16

17 Li’s private messages to Sadeghi, on Facebook, on January 19, 2017: 18 • 19 [January 19, 2017] Li: “I talked with [one of Pinscreen’s co-founders and board

20 members] and [one of Pinscreen’s VC partners from Lux Capital] etc.” • 21 [January 19, 2017] Li: “They really like you and we really want you to join us, currently our company is receiving increased valuation” 22 23 24

25 Li’s private message to Sadeghi, on Facebook, on January 19, 2017: 26 • [January 19, 2017] Li: “I think you should join” 27 28 68 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li’s private message to Sadeghi, on Facebook, on January 21, 2017: 2 • [January 21, 2017] Li: “[…] you will make sure to take a leadership role as VP of 3 Engineering (potentially having a more important role than CTO), meaning 4 coordinating teams and also ensuring efficient deliverables, etc. […]” 5 6 7

8 Li’s private message to Sadeghi, on Facebook, on January 22, 2017

9 • [January 22, 2017] Li: “Most importantly we need you to help me oversee the 10 technology [development] of everyone and push it to the next level” 11 12

13 The “Stock Option Plan” in Sadeghi’s employment contract with Pinscreen, signed by Li and 14 Sadeghi, on January 23, 2017. The full employment contract is available in Exhibit G: 15 • “Subject to the approval of the Company's Board of Directors (the 'Board'), the Company 16 shall grant you a stock option covering the number shares of the Company's Common 17 Stock equivalent to 2.3% of the outstanding shares of the Company (the 'Option'). 18 The Option shall be granted as soon as reasonably practicable after the date of this 19 Agreement or, if later, the date you commence full-time Employment. The exercise price 20 per share will be equal to the fair market value per share on the date the Option is granted, 21 as determined by the Company's Board of Directors in good faith compliance with 22 applicable guidance in order to avoid having the Option be treated as deferred 23 compensation under Section 409A of the Internal Revenue Code of 1986, as amended. 24 There is no guarantee that the Internal Revenue Service will agree with this value. You 25 should consult with your own tax advisor concerning the tax risks associated with 26 accepting an option to purchase the Company's Common Stock. The term of the Option 27 shall be 10 years, subject to earlier expiration in the event of the termination of your 28 services to the Company. So long as your Employment is continuous, the Option shall 69 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 vest and become exercisable as follows: 1/4 of the total number of option shares shall 2 vest and become exercisable on the first anniversary of the Option grant date. Thereafter, 3 the unvested shares shall vest quarterly over a three-year period in equal increments. The 4 Option will be an incentive stock option to the maximum extent allowed by the tax code 5 and shall be subject to the other terms and conditions set forth in the Company's 2015 6 Stock Option Plan (the 'Stock Plan') and in the Company's standard form of Stock Option 7 Agreement (the 'Stock Agreement').”

8 • “Furthermore, the Company shall negotiate with you in good faith regarding an 9 additional stock option grant following the consummation by the Company of its 10 Series A round of financing to counteract the dilutive effect on you of such 11 financing.” 12 13 14 15 16 17 18 19 20 21

22 Li’s private e-mail to Sadeghi, with subject “Stock Option Info,” on February 18, 2017: 23 • [February 18, 2017] Li: “1. The current exercise price is $1.10 per share” 24 • [February 18, 2017] Li: “2. Iman [Sadeghi] will get up to 14,375 shares which is 25 2.3% of the outstanding shares and the shares reserved for the option pool. After the 26 first year, he will get 1/4 of these shares = 3594 shares. After four years, he will get 27 all of 14,375.” 28 70 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [February 18, 2017] Li: “Cheers,” 2 • [February 18, 2017] Li: “Hao [Li]” 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 71 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT C 2 Li’s and Pinscreen’s Fraud and Deceit of Sadeghi 3 Li’s private conversation with Sadeghi, in writing, on Facebook, on January 22, 2017, when 4 Li misrepresented manually prepared avatars as automatic to Sadeghi:

5 • [January 22, 2017, at 3:39 p.m.] Li: “Okay let me show you some shit” 6 • [January 22, 2017, at 3:39 p.m.] Li: “That will get [you] excited” 7 • [January 22, 2017, at 3:39 p.m.] Sadeghi: […] 8 • [January 22, 2017, at 3:39 p.m.] Li: “That’s the thing I wanted to show you”

9 • [January 22, 2017, at 3:39 p.m.] Sadeghi: “Cool. Let’s see it 🙂🙂” 10 • [January 22, 2017, at 3:39 p.m.] Li: [Input image] 11 • [January 22, 2017, at 3:39 p.m.] Li: “Input” 12 • [January 22, 2017, at 3:39 p.m.] Li: “Output” 13 • [January 22, 2017, at 3:40 p.m.] Li: [Output avatar] 14 • [January 22, 2017, at 3:40 p.m.] Li: “Input” 15 • [January 22, 2017, at 3:40 p.m.] Li: [Input image] 16 • [January 22, 2017, at 3:40 p.m.] Li: “Output” 17 • [January 22, 2017, at 3:40 p.m.] Li: [Output avatar] 18 • [January 22, 2017, at 3:40 p.m.] Li: “Ahahaha”

19 • [January 22, 2017, at 3:40 p.m.] Li: “And so on and so on” 20 • [January 22, 2017, at 3:41 p.m.] Li: “We are porting this pipeline to the server right 21 now, so that we don't have to compute everything on our PCs [Personal Computers]”

22 • [January 22, 2017, at 3:41 p.m.] Li: “[a Pinscreen Employee] is also done in 2 weeks 23 with UX [User Interface/User Experience]”

24 • [January 22, 2017, at 3:41 p.m.] Sadeghi: “Wow! This is awesome! 🎯🎯” 25 • [January 22, 2017, at 3:41 p.m.] Li: “And backend” 26 • [January 22, 2017, at 3:41 p.m.] Li: “Another urgent item is Avatar 2” 27 • [January 22, 2017, at 3:42 p.m.] Li: “We will be working on the real-time face tracking 28 for all the Navii's” 72 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [January 22, 2017, at 3:42 p.m.] Li: “Okay [let me] write the lawyer to get you the 2 contract”

3 • [January 22, 2017, at 3:43 p.m.] Sadeghi: “Omg! So good! This is well done! Pre- 4 defined models for eyes and teeth? Autogenerated hair?”

5 • [January 22, 2017, at 3:43 p.m.] Li: “Yes” 6 • [January 22, 2017, at 3:44 p.m.] Li: “But needs improvement” 7 • [January 22, 2017, at 3:44 p.m.] Li: “The quality can still be improved” 8 • [January 22, 2017, at 3:44 p.m.] Li: “And robustness as well” 9 • [January 22, 2017, at 3:44 p.m.] Li: “We also have tongue animations” 10 • [January 22, 2017, at 3:44 p.m.] Li: “Everything” 11 • [January 22, 2017, at 3:44 p.m.] Li: “Would be cool if we could do something for 12 Valentine’s day, but not sure if we can make it”

13 • [January 22, 2017, at 3:45 p.m.] Sadeghi: “I was thinking something like this would 14 be down the road. Very impressive early results.” 15 16 17 18 19 20 21 22 23 24 25 26 27 28 73 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

22 23 24 25 26 27 28 74 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

23 24 25 26 27 28 75 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14

15

16 Before Sadeghi’s employment at Pinscreen: 17 Li’s private message to Sadeghi, on Facebook, on December 26, 2016:

18 • [December 26, 2016]: Li: “So current value is 30M especially since we have built all 19 the backend platform for user creation and a [technology] that is state of the art” 20 21

22 Before Sadeghi’s employment at Pinscreen: 23 Li’s private messages to Sadeghi, on Facebook, on January 19, 2017: 24 • [January 19, 2017] Li: “[By the way] the [technology] is super duper cool now” 25 • [January 19, 2017] Li: “Lots of things [have] changed since last time [you] visited” 26 • [January 19, 2017] Li: “High-quality hair” 27 • [January 19, 2017] Li: “High-quality face models” 28 76 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [January 19, 2017] Li: “High-quality animations” 2 3 4 5

6

7 After Sadeghi joined Pinscreen: 8 Li’s private messages to Sadeghi, on Facebook, on March 1, 2017: 9 • 10 [March 1, 2017] Li: “I made a quick [evaluation]:” • 11 [March 1, 2017] Li: […] • 12 [March 1, 2017] Li: “Hair -> shit” • 13 [March 1, 2017] Li: “Rendering -> shit” • 14 [March 1, 2017] Li: “Eye ball fitting -> shit” • 15 [March 1, 2017] Li: “Teeth -> good” • 16 [March 1, 2017] Li: “Face fitting -> good” • 17 [March 1, 2017] Li: “Hair segmentation -> good but query/fitting complete crap”

18 19 20 21 22 23 24 25 26 27 28 77 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 After Sadeghi joined Pinscreen: 2 Li’s group messages, on “Pinscreen” thread, on Facebook, to Sadeghi and multiple other 3 participants, on March 13, 2017:

4 • [March 13, 2017] Li: “Most important thing right now is:” 5 • [March 13, 2017] Li: “1) Avatar hair reconstruction is shit” 6 • [March 13, 2017] Li: “2) Shading rendering is not good enough” 7 • [March 13, 2017] Li: “3) Too slow” 8 • [March 13, 2017] Li: “Not robust enough” 9 10 11 12 13

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 78 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT D 2 Sadeghi’s Contributions 3 Feedback from conference reviewers about Pinscreen’s SIGGRAPH 2017 Technical Papers 4 submission, submitted on January 16, 2017, before Sadeghi’s employment at Pinscreen. This 5 submission was subsequently rejected.

6 • [Conference Reviewer]: “Compared with state-of-the-art avatar generation techniques 7 that all requires multiple images as input, the described system only needs a single image, 8 which makes it more appealing to consumer applications. However, the novelty of the

9 work and the quality of the generated avatars are below the SIGGRAPH standard.” 10 11

12 • [Conference Reviewer]: “Results presented in the paper and video are not satisfactory. 13 A lot of disturbing artifacts (e.g. in regions around the silhouette) can be observed in 14 almost all hair models shown in the paper. I seriously doubt if the quality is good 15 enough for games or VR [Virtual Reality] applications. For the comparisons shown 16 in Fig. 11, I'd like to see the full models in the video. I also want to see the comparisons 17 between AutoHair and the present system. It's also necessary to rotate the models to let 18 people see the back side of the models.” 19 20 21

22 Question from one of the conference reviewers about Pinscreen’s SIGGRAPH Asia Technical 23 Papers submission, submitted on May 23, 2017, after Sadeghi’s contribution to Pinscreen’s hair 24 appearance. This submission was subsequently accepted: 25 • [Conference Reviewer]: “#11 Q: Why the quality is so improved comparing [sic] with 26 previous submission.” 27 • [Pinscreen’s Answer]: “A: For the hair, our previous submission only used a primitive 28 79 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 hair texture rendering based on Blinn-Phong shading and transparency ordering was not

2 implemented. In this submission, hair shading has been significantly improved using 3 a variant of Sadeghi 2010 (used in Disney's Tangled) and […]” 4 5 6

7 A comparison of Pinscreen’s digital hair appearance before and after Sadeghi’s contributions 8 to Pinscreen’s digital hair appearance: 9 10 11 12 13

14 Input Image 15 Before After Sadeghi’s Contributions to Sadeghi’s Contributions to 16 Pinscreen’s Hair Appearance Pinscreen’s Hair Appearance 17 18 19 20 21 22 23 24 25 26

27 Pinscreen’s Submission to Pinscreen’s Submission to SIGGRAPH on January 16, 2017 SIGGRAPH Asia on May 23, 2017 28 [Rejected] [Accepted] 80 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Before After 2 Sadeghi’s Contributions to Sadeghi’s Contributions to Pinscreen’s Hair Appearance Pinscreen’s Hair Appearance 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

25 26 Pinscreen’s Submission to Pinscreen’s Submission to SIGGRAPH on January 16, 2017 SIGGRAPH Asia on May 23, 2017 27 [Rejected] [Accepted] 28 81 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Sadeghi’s contributions to Pinscreen’s hair shape estimation through obtaining Semantic 2 Constraints using Deep Convolutional Neural Networks and Artificial Intelligence (“AI”):

3 • Sadeghi’s contributions regarding Pinscreen’s Hair Recognition 2.0:

4 o http://docs.google.com/a/pinscreen.com/document/d/1TbVH6yhIjqvOTz-B_- 5 qqCSQ7AFHVzl_inbbIB7Bdfb0/edit

6 • Sadeghi’s contributions regarding Pinscreen’s Hair Recognition 2.0 Training Data:

7 o http://docs.google.com/a/pinscreen.com/document/d/1I_971F8a43_Mn5No_bdG4 8 SXyJGFm7YIcRjs0V7BkTOk/edit 9

10 Li’s group messages, on Skype, on April 18, 2017, leading up to SIGGRAPH Asia Technical 11 Papers submission due on May 23, 2017, to Sadeghi and another Pinscreen employee, who later 12 became a first author of the publication:

13 • [April 18, 2017] [a Pinscreen employee]: “But this Semantic Constraints could add 14 biggest contribution”

15 • [April 18, 2017] Li: “Vi [sic] need to find 10 hair cases” 16 • [April 18, 2017] Li: “Yes, what I’m saying is that we [don’t] need to specify all the 17 details”

18 • [April 18, 2017] Li: “Just like when [you] say FACS” 19 • [April 18, 2017] Li: “[You] [don’t] say which expressions”

20 • [April 18, 2017] [the Pinscreen employee]: “Yes, that makes sense” 21 • [April 18, 2017] Li: “But first it has to work”

22 • [April 18, 2017] Li: “We need to make sure that people cannot easily implement it” 23 • [April 18, 2017] Li: “Maybe we add a lot of things about the hair cutting etc.” 24 25 26 27 28 82 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13

14 Sadeghi’s contributions regarding Pinscreen’s System Architecture: 15 • http://docs.google.com/a/pinscreen.com/document/d/1Efej_qLs_4M3ieA0qotLkQqy40 16 gEF_R-_V8pROLlZUY/edit 17

18 Sadeghi’s contributions regarding Pinscreen’s Code Health: 19 • http://docs.google.com/a/pinscreen.com/document/d/1ozO4Nb- 20 H5b4wy0glQm9k2Q8b60yhgorpC1PdanOjDtQ/edit 21

22 Sadeghi’s contributions regarding Pinscreen’s Codebase Structure: 23 • http://docs.google.com/a/pinscreen.com/document/d/1bCNqLQDSuFPxqTReKBR5tIw 24 vXgsj84FpUgvmZEf0C9A/edit 25

26 Sadeghi’s contributions regarding Pinscreen’s System Security: 27 • http://docs.google.com/a/pinscreen.com/document/d/1w7ow9PW4HTBE5UilkoROQ4 28 83 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 h6CchxQbpoWNXjZZ2WH5c/edit 2

3 Sadeghi’s contributions regarding Pinscreen’s User Interface/User Experience (UI/UX):

4 • http://docs.google.com/a/pinscreen.com/document/d/1w7TLtCK7fTUk1dQIN20e- 5 d48Oxem0O9PsJ1_k-SqzsQ/edit 6

7 Sadeghi’s contributions regarding Pinscreen’s Mobile Apps:

8 • http://docs.google.com/a/pinscreen.com/document/d/1W2BudSk5fB1lYzCQz0OzL_A 9 080n1vZPGoNCSxf6ICcQ/edit 10

11 Sadeghi’s contributions regarding Pinmojis (i.e. Pinscreen Emojis):

12 • http://docs.google.com/a/pinscreen.com/document/d/1NzwUpKXjYyhGsCHokcRCMT 13 gKg3OC5ftFgBHlA5IjcgU/edit 14

15 Sadeghi’s planning and coordinating regarding Pinmoji Product Launch deliverables and 16 timeline:

17 • http://docs.google.com/a/pinscreen.com/document/d/1iUPehGf9oTnWUV7SRuFnP9Q 18 WU-KEopOvMK-ivdaUqQE/edit 19

20 Sadeghi’s planning and coordinating regarding Pinscreen’s SIGGRAPH 2017 Real-Time 21 Live (RTL) deliverables and timeline:

22 • http://docs.google.com/a/pinscreen.com/document/d/1VOY9eDxirYK5NKd8RUAiLu 23 W__mFKpZQKBhfbveqLnAw/edit 24

25 Sadeghi’s planning and coordinating regarding Pinscreen’s A2 Project deliverables and 26 timeline:

27 • http://docs.google.com/a/pinscreen.com/document/d/1po3HvDQQKlIjvaCDveK4wfkP 28 5Rwa-Rb2RQiJZBoBuow/edit 84 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li’s private messages to Sadeghi, on Skype, on April 17, 2017:

2 • [April 17, 2017] Li: “Also might be good to sync with [Pinscreen’s CTO] about his 3 status”

4 • [April 17, 2017] Li: “And make sure he [the CTO] reports to you [Sadeghi] about 5 what his progress is” 6 7 8 9 10 11

12 Sadeghi’s group messages, on “PinscreenTeamAll” thread, on Skype, with 14 other 13 participants, on July 14, 2017, around sunrise, when he had worked overnight with another 14 Pinscreen employee: 15 • [July 14, 2017 at 6:19 a.m.] Sadeghi: [a photo of the sunrise] 16 • [July 14, 2017 at 6:19 a.m.] Sadeghi: “How do you start your day? 😄😄” 17 • [July 14, 2017 at 6:21 a.m.] Sadeghi: “[the other Pinscreen employee] and I are 18 rotating Spherical Harmonics! 🌞🌞” 19 20 21 22 23 24 25 26 27 28 85 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11

12

13 Sadeghi’s group message, on “PinscreenTeamAll” thread, on Skype, with 14 other participants, 14 on the same day, on July 14, 2017, early in the morning: 15 • [July 14, 2017 at 7:49 a.m.] Sadeghi: “Also, [the other Pinscreen employee] and I 16 are still dealing with the Spherical Harmonics issues …” 17 18 19 20 21 22

23 Pinscreen employees’ group messages, on “PinscreenTeamAll” thread, on Skype, shared with 24 Sadeghi and 14 other participants, later on the same day, on July 14, 2017, congratulating 25 Sadeghi and the other employee in resolving the issue with Spherical Harmonics (“SH”). 26 Sadeghi was going to sleep in the morning after an 18-hour work shift overnight: 27 • 28 [July 14, 2017] [a Pinscreen officer]: “Really great results! Awesome you got it to 86 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 work! And dynamic SH doesn’t seem to be a problem all!”

2 • [July 14, 2017] [another Pinscreen employees]: “Congrats 👍👍” 3 • [July 14, 2017] Sadeghi: “It was such an intense night. [the other Pinscreen

4 employee] and I will high five differently after this!🎉🎉” 5 • [July 14, 2017] Sadeghi: “Just got home safe. Going to sleep now 😄😄” 6 • [July 14, 2017] Li: “Awesome thanks for the hard work!” 7 8 9 10 11 12 13 14 15 16 17 18

19 20 21 22 23 24 25 26 27 28 87 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT E 2 Li’s and Pinscreen’s Data Fabrication and Academic Misconduct 3 Li’s private conversation with Sadeghi, on Facebook, on February 4, 2017, regarding one of 4 the Computer Science professors at USC:

5 • [February 4, 2017] Li: “Because his current Ph.D. advisor [a USC professor and an 6 Academy Scientific and Technical (Sci-Tech) Award winner] would block him from 7 graduating if he joins Pinscreen”

8 • [February 4, 2017] Li: “[the USC professor] is super jealous of what we do here” 9 • [February 4, 2017] Li: “[the USC professor] is like [a political figure]” 10 • [February 4, 2017] Sadeghi: “Good to know about the VR politics!”

11 • [February 4, 2017] Li: “Just a bunch of academic loosers [sic] 🙂🙂” 12 13 14 15 16

17

18 Li’s private messages to Sadeghi, on Skype, on June 5, 2017, regarding another Computer 19 Science professor at USC:

20 • [June 5, 2017] Li: “Because his advisor [another USC professor] does not want him to 21 join us”

22 • [June 5, 2017] Li: “[the other USC professor] is jealous” 23 24 25 26 27

28 88 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li’s group conversation with a Pinscreen employee, on “SIGRTL-F2F Tracking” thread, on 2 Skype, shared with Sadeghi and 8 other participants, on June 21, 2017, leading up to 3 SIGGRAPH RTL public demo on August 1, 2017:

4 • [June 21, 2017] [a Pinscreen employee]: “What do [you] mean it’s difficult to say what 5 is good and bad data[?]”

6 • [June 21, 2017] Li: “What I mean is that it’s not easy to tell how to tweak data to get 7 the results we want”

8 • [June 21, 2017] Li: “Actually you know what? Fuck it” 9 • [June 21, 2017] Li: “Just [do] what you want” 10 • [June 21, 2017] Li: “I [don’t] give a shit” 11 • [June 21, 2017] Li: “It’s a total waste of time discussing with you” 12 13 14 15 16 17 18 19 20 21

22 Li’s group messages, on “Pinscreen Team” thread, on Skype, shared with Sadeghi and 9 other 23 participants, on March 27, 2017, leading up to SIGGRAPH RTL submission due on April 4, 24 2017: 25 • [March 27, 2017] Li: “But what I’m saying is that we should [collect] it, then we know 26 something” 27 • [March 27, 2017] Li: “The issue is that we don’t have time” 28 • [March 27, 2017] Li: “We should start the collection ASAP” 89 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [March 27, 2017] Li: “Items are:” 2 • [March 27, 2017] Li: “1) Classification” 3 • [March 27, 2017] Li: “We have never done this before, so no idea how long that will 4 take”

5 • [March 27, 2017] Li: “2) We [don’t know] if handpicked are good” 6 • [March 27, 2017] Li: “3) we still need hair rendering” 7 • [March 27, 2017] Li: “4) we also need some tracking” 8 • [March 27, 2017] Li: “It’s basically 1 day per task” 9 • [March 27, 2017] Li: “If we don’t parallelize it, there is no way we can make it”

10 • [March 27, 2017] Li: “Even if we fake things there is no time” 11 12 13 14 15 16 17 18 19 20 21 22 23

24 Li’s group messages, on “RTL Demo […]” thread, on Skype, shared with Sadeghi and 6 other 25 participants, on March 27, 2017, leading up to SIGGRAPH RTL submission due on April 4, 26 2017: 27 • [March 27, 2017] Li: “Yes” 28 90 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [March 27, 2017] Li: “We need a feasibility discussion first” 2 • [March 27, 2017] Li: “I have doubts for now”

3 • [March 27, 2017] Li: “We could build the model on time (via cheating)” 4 5 6 7 8 9 10 11

12

13 Li’s group messages, on “VR Hair Modeling” thread, on Skype, shared with Sadeghi and 8 14 other participants, on June 29, 2017, leading up to SIGGRAPH RTL rehearsal on July 7, 2017:

15 • [June 29, 2017] Li: “Okay let’s push for the pipeline first”: 16 • [June 29, 2017] Li: “And not fine tune”:

17 • [June 29, 2017] Li: “I’m really worried that nothing will work by [the] rehearsal 18 and we have to [do] some shitty cheating again” 19 20 21 22 23 24 25

26

27 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 28 91 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 other participants, on May 15, 2017, leading up to SIGGRAPH Asia Technical Papers 2 submission due on May 23, 2017:

3 • [May 15, 2017] Li: “Our eyes are wrong” 4 • [May 15, 2017] Li: “The colors” 5 • [May 15, 2017] Li: “We need to use a Deep Neural [Network] for that” 6 • [May 15, 2017] [a Pinscreen officer]: “For the SIGAsia paper”

7 • [May 15, 2017] Li: “Or we just do it manually for SIGGRAPH Asia for now” 8 • [May 15, 2017] [the Pinscreen officer]: “Do you need Unity rendering”

9 • [May 15, 2017] Li: “Let’s do it manually for now” 10 • [May 15, 2017] Li: “I think it’s the only way” 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

26 Li’s group messages, on “RTL Demo […]” thread, on Skype, shared with Sadeghi and 6 other 27 participants, on March 27, 2017, leading up to SIGGRAPH RTL submission due on April 4, 28 2017: 92 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [March 27, 2017] Li: “It’s even better to have not good looking hair real-time than 2 good looking non real-time hair”

3 • [March 27, 2017] Li: “But we should try to have some hair if we want to try to aim for 4 it”

5 • [March 27, 2017] Li: “The reconstruction part we probably have no choice but to 6 cheat” 7 8 9 10 11 12 13 14

15

16 Li group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 other 17 participants, on May 22, 2017, one day before SIGGRAPH Asia Technical Papers submission 18 due on May 23, 2017:

19 • [May 22, 2017] Li: “What’s the current ETA?” 20 • [May 22, 2017] Li: “I need it to see if we [shouldn’t] do something else?”

21 • [May 22, 2017] Li: “We are late by 6 hours” 22 • [May 22, 2017] Li: “We almost don’t [have] time to produce results and write the 23 paper”

24 • [May 22, 2017] Li: “If in an hour it’s not working let’s do it manually” 25 • [May 22, 2017] Li: “And give up on it” 26 • [May 22, 2017] Li: “I don’t think we can make it automatic” 27 28 93 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11 Article published by Venture Square on August 29, 2017:

12 • Title: “Softbank Ventures Invests in US Graphics Startup Pinscreen” 13 • URL: http://www.venturesquare.net/world/softbank-ventures-pinscreen

14 • [August 29, 2017] Venture Square: “Softbank Ventures has invested in AI graphics 15 startup Pinscreen in a funding round together with Lux Capital and Colopl Next.”

16 • [August 29, 2017] Venture Square: “The technology has been recognized by 17 SIGGRAPH, one of the top authorities in the computer graphics industry, as one of 18 the most innovative developments this year.” 19

20 Li’s private messages to Sadeghi, on Skype, on April 26, 2017:

21 • [April 26, 2017] Li: “If we just get a TechCrunch article on our stuff, then the 22 valuation could be much higher”

23 • [April 26, 2017] […]

24 • [April 26, 2017] Li: “Much higher = 5-10x” 25 26 27 28 94 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5

6 … 7

8 Li’s private message to Sadeghi, on Skype, on May 22, 2017: 9 • [May 22, 2017] Li: “TechCrunch coverage should be our target” 10 11 12 13 14 15

16 Li’s group message, on “SIGRTL-F2F-Tracking” thread, on Skype, shared with Sadeghi and 8 17 other participants, on June 17, 2017, regarding SIGGRAPH RTL on August 1, 2017: 18 • [June 17, 2017] Li: “There will be TechCrunch at SIGGRAPH RTL” 19

20 21 22 23 24 25

26 Li’s group messages, on “RTL Demo […]” thread, on Skype, shared with Sadeghi and 6 other 27 participants, on March 30, 2017, leading up to SIGGRAPH RTL submission due on April 4, 28 95 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2017:

2 • [March 30, 2017] Li: “I just interviewed and hired a hair [modeler]” 3 • [March 30, 2017] Li: “He’ll try to get us something by [tomorrow] this time, or a bit 4 later”

5 • [March 30, 2017] Li: “And by Monday these five hair models” 6 • [March 30, 2017] Li: [leszek.zip] 7 • [March 30, 2017] […]

8 • [March 30, 2017] Li: “I am asking an artist to create them from scratch” 9 • [March 30, 2017] Li: “And will fix them in parallel”

10 • [March 30, 2017] Li: “We need to think of a solution, artists are too slow and 11 expensive”

12 • [March 30, 2017] Li: “I’ll ask him create 5 for now” 13 • [March 30, 2017] Li: “100 Euro[s] per hair” 14 • [March 30, 2017] Li: “3 hours per hair they need” 15 16 17 18 19 20 21 22 23

24 … 25 26 27 28 96 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6

7 Leszek’s group messages, on Skype, to Li and Sadeghi, on April 18, 2017, when he shared his 8 previously manually created hair models (i.e. hair shapes): 9 • [April 18, 2017] Leszek: [Ryan_003.zip containing Ryan_003.obj] 10 • [April 18, 2017] Leszek: [Haley_017.zip containing Haley_017.obj] 11 • [April 18, 2017] Leszek: [Cosimo_014.zip containing Cosimo_014.obj] 12 • [April 18, 2017] Leszek: [Jackie_020.zip containing Jackie_020.obj] 13 • [April 18, 2017] Leszek: [Phil_022.zip containing Phil_022.obj] 14 15 16 17 18 19 20 21 22

23

24 Following diagram, displays supposedly automatic avatars, presented in Pinscreen’s

25 SIGGRAPH RTL submission on April 4, 2017, for Ryan Gosling (left) and Haley Dunphy 26 (right) with hand-made hair models, by freelance artist Leszek, misrepresented as automatic: 27 28 97 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Fabricated avatars submited by Pinscreen, on April 4, 2017, to SIGGRAPH RTL 2 3 4 5 6 7 Ryan Gosling Haley Dunphy 8 (Actor) (Fictional Character)

9 On information and belief, Pinscreen’s technology has been and still is, as of June 11, 2018, 10 after more than a year since the submission, incapable of automatically generating hair shapes 11 with intricacies demonstrated in Leszek’s hand-made hair shape for Haley’s avatar 12 (Haley_017.obj). 13

14 Li’s group messages, on “R&D Weekly” thread, on Skype, shared with Sadeghi and 10 other 15 participants, on March 29, 2017, regarding the title for Pinscreen’s SIGGRAPH RTL 16 submission due on April 4, 2017:

17 • [March 29, 2017] Li: “From Previs to Final in Five minutes: A Breakthrough in Live 18 Performance Capture”

19 • [March 29, 2017] Li: “Pinscreen: Creating Animated Avatars without Artists in 5 20 seconds”

21 • [March 29, 2017] Li: “Avatar Digitization from a Single Image” 22 • [March 29, 2017] [a Pinscreen officer]: “Pinscreen: 3D Avatar from a Single Image”

23 • [March 29, 2017] Li: “Pinscreen: Creating Performance-Driven Avatars in 24 seconds”

25 • [March 29, 2017] [📞📞 Call ended, duration 1 hour, 22 minutes, and 58 seconds] 26 27 28 98 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13

14 A frame of the video submitted to SIGGRAPH RTL, on April 4, 2017, by Pinscreen, stating 15 that the speed of avatar generation is “a few seconds”: 16 • “Wait a few seconds … it’s building the face and the hair automatically.” 17 18 19 20 21 22 23 24 25

26 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 27 other participants, on May 15, 2017, leading up to SIGGRAPH Asia Technical Papers 28 99 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 submission due on May 23, 2017:

2 • [May 15, 2017] Li: [SIGA17 TODO LIST Document] 3 • [May 15, 2017] Li: “- Evaluate/compare for choice of hair system (comparison to 4 AutoHair)”

5 • [May 15, 2017] Li: “- Explain how the eye balls, mouth was chosen”

6 • [May 15, 2017] Li: “- Present all the results for 100 tested photos” 7 • [May 15, 2017] Li: “- Explain how the chosen blend shapes method affects the animation 8 across diverse people”

9 • [May 15, 2017] Li: “Present full models, front and back views” 10 • [May 15, 2017] Li: “Show comparison to Loom.ai” 11 12 13 14 15 16 17 18 19 20 21 22 23

24 Li’s group messages, on Skype, to Sadeghi and another Pinscreen employee, on April 18, 2017, 25 leading up to SIGGRAPH Asia Technical Papers submission due on May 23, 2017: 26 • [April 18, 2017] Li: “Hey [a Pinscreen employee]” 27 • [April 18, 2017] Li: “For SIGGRAPH Asia” 28 100 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [April 18, 2017] Li: “We need 100 fitted faces” 2 • [April 18, 2017] Li: “Do [you] think [you] can prepare a database for benchmarking” 3 • [April 18, 2017] Li: “Based on what we have?” 4 • [April 18, 2017] [the Pinscreen employee]: “Sure” 5 • [April 18, 2017] Li: “Then we can aim for that too, so the others can focus on hair” 6 • [April 18, 2017] Li: “So maybe it would be good to select 100 faces and we have 7 similar hairstyles that correspond to our selection thing”

8 • [April 18, 2017] Li: “Then I have an artist create all 100 hairs” 9 • [April 18, 2017] Li: “Ahahaha” 10 11 12 13 14 15 16 17 18 19 20 21

22

23 Li’s private messages to Sadeghi, on Skype, on May 17, 2017, regarding the “High Priority” 24 tasks leading up to SIGGRAPH Asia Technical Papers submission due on May 23, 2017:

25 • [May 17, 2017] Li: “High Priority” 26 • [May 17, 2017] Li: […]

27 • [May 17, 2017] Li: “11) Hao [Li]: get hair models for all 100 results (hard)” 28 • [May 17, 2017] Li: […] 101 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

16 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 17 other participants, on May 17, 2017, leading up to SIGGRAPH Asia Technical Papers 18 submission due on May 23, 2017, regarding task number 11 (i.e. “Hao [Li]: get hair models for 19 all 100 results”) mentioned above: 20 • [May 17, 2017] Li: “How can do 11 [get hair models for all 100 results]?” 21 • [May 17, 2017] Li: “[You] can model in 3D?” 22 • [May 17, 2017] [a Pinscreen officer]: “Arh! 😁😁” 23 • [May 17, 2017] [the Pinscreen officer]: “No” 24 • [May 17, 2017] [the Pinscreen officer]: “sorry” 25 • [May 17, 2017] Li: “So basically I need to create 3D hair models for 100 people” 26 • [May 17, 2017] Li: “Or get 3D modelers to do it” 27 28 102 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12

13 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 14 other participants, on May 18, 2017, leading up to SIGGRAPH Asia Technical Papers 15 submission due on May 23, 2017: 16 • [May 18, 2017] Li: “Okay so I’m generating all the avatars” 17 • [May 18, 2017] Li: “We need someone to manually fix all the eye colors” 18 19 20 21 22 23 24

25 Li’s group message, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 26 other participants, on May 18, 2017, leading up to SIGGRAPH Asia Technical Papers 27 submission due on May 23, 2017: 28 103 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [May 18, 2017] Li: “We also need someone to manually adjust the eye colors” 2 3 4 5 6 7

8

9 Li’s group conversation with another Pinscreen officer, on “PinscreenTeamAll” thread, on 10 Skype, shared with Sadeghi and 4 other participants, on May 18, 2017, leading up to 11 SIGGRAPH Asia Technical Papers submission due on May 23, 2017:

12 • [May 18, 2017] Li: “The eye color is total shit” 13 • [May 18, 2017] Li: “It’s completely random” 14 • [May 18, 2017] [a Pinscreen officer]: “I know 🙂🙂” 15 • [May 18, 2017] Li: “We really need a better algorithm” 16 • [May 18, 2017] [the Pinscreen officer]: “But at least its quick to implement” 17 • [May 18, 2017] Li: “Yeah” 18 • [May 18, 2017] [the Pinscreen officer]: “But do we have time for a new [algorithm]?” 19 • [May 18, 2017] Li: “I guess a Deep Neural [Network] would have been the way to go” 20 • [May 18, 2017] [the Pinscreen officer]: “So no 😁😁” 21 • [May 18, 2017] Li: “I would say medium priority”

22 • [May 18, 2017] Li: “I would say let’s do them manually for now” 23 24 25 26 27 28 104 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

18 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 19 other participants, on May 18, 2017, leading up to SIGGRAPH Asia Technical Papers 20 submission on May 23, 2017: 21 • 22 [May 18, 2017] Li: “What’s the status with the hair texture part?” • 23 [May 18, 2017] Li: “[By the way] I’m regenerating all the 160 faces” • 24 [May 18, 2017] Li: “Because of the spacing issue only 122 were generated” • 25 [May 18, 2017] Li: “I will upload Dropbox folder once I’m done” • 26 [May 18, 2017] Li: “Then need [a Pinscreen employees] to work on eye colors” • 27 [May 18, 2017] Li: “[another Pinscreen employee] on focal length adjustments per person” 28 105 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11 Pinscreen’s claims in its SIGGRAPH Asia 2017 Technical Papers publication: 12 • The effectiveness of our methodology is grounded on a careful integration of state-of- 13 the-art modeling and synthesis techniques, for faces and hair. Several key components, 14 such as segmentation, semantic hair attributes extraction, and eye color recognition are 15 only possible due to recent advances in deep learning. Our experiments also indicate 16 the robustness of our system, where consistent results of the same subject can be obtained 17 when captured from different angles, under contrasting lighting conditions, and with 18 different input expressions.” 19 20 21 22 23 24

25 A group message from a Pinscreen employee, on “PinscreenTeamAll” thread, on Skype, shared 26 with Sadeghi and 14 other participants, on May 19, 2017, leading up to SIGGRAPH Asia 27 Technical Papers submission due on May 23, 2017, outlining some of the remaining tasks and 28 106 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 the names of the employees assigned to each task:

2 • [May 19, 2017] [a Pinscreen employee]: “Hairs to do:” 3 • [May 19, 2017] [the Pinscreen employee]: […] 4 • [May 19, 2017] [the Pinscreen employee]: “Rendering” 5 • [May 19, 2017] [the Pinscreen employee]: […]

6 • [May 19, 2017] [the Pinscreen employee]: “Load hair color from txt file” 7 • [May 19, 2017] [the Pinscreen employee]: “Manually pickup hair color and store it 8 in .txt in Hex ([a Pinscreen officer])” 9 10 11 12 13 14 15 16 17 18 19 20 21 22

23

24 Pinscreen’s claims in its SIGGRAPH Asia 2017 Technical Papers publication: 25 • “The eye color texture (black, brown, green, blue) is computed using a similar 26 convolutional neural network for semantic attributes inference as the one used for 27 hair color classification.” 28 107 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2

3 Li’s private messages to Sadeghi, on Skype, on February 27, 2017: 4 • [February 27, 2017] Li: “Let me tell you” 5 • [February 27, 2017] Li: “RTL is the best event at SIGGRAPH” 6 • [February 27, 2017] Li: “It’s [a] big show” 7 • [February 27, 2017] Li: “Much more visibility than papers” 8 9 10 11 12 13 14

15 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 16 other participants, on June 1, 2017:

17 • [June 1, 2017] Li: “Real-Time Live” 18 • [June 1, 2017] Li: “It’s the hardest thing to get in” 19 • [June 1, 2017] Li: “It’s much harder than paper[s]” 20 21 22 23 24 25 26 27 28 108 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 2 other participants, on June 1, 2017: 3 • [June 1, 2017] Li: “If someone asks you at SIGGRAPH if you have a SIGGRAPH paper, 4 you say we don’t always publish papers but when we do, we go straight to Real- 5 Time Live!” 6 • [June 1, 2017] Li: “It’s the only show that matters at SIGGRAPH” 7 • [June 1, 2017] Li: “We did the minimum work to get it in” 8 • [June 1, 2017] Li: “We were one spot away” 9 • [June 1, 2017] Li: “Baker baker!” 10 • [June 1, 2017] Li: “Baker baker!” 11 • [June 1, 2017] Li: “Mamamamammama ma er duo” 12 • [June 1, 2017] Li: “Ma er duo!” 13 • [June 1, 2017] Li: “Avatar” 14 • [June 1, 2017] Li: “Let me tell you” 15 16 17 18 19 20 21 22 23 24 25 26 27

28 109 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 2 other participants, on May 5, 2017, regarding the speed and capabilities of the competitor 3 company Loom.ai, while Li was at the FMX 2017 conference (May 2, 2017 to May 5, 2017) 4 for a presentation:

5 • [May 5, 2017] Li: “Loom.ai needs 1:30 min to reconstruct face” 6 • [May 5, 2017] Li: “Quality is still the same as the one they have released” 7 • [May 5, 2017] Li: “So we beat them in terms of face accuracy”

8 • [May 5, 2017] Li: “They have no solution for hair yet” 9 • [May 5, 2017] Li: “They are planning to do Loomojis” 10 • [May 5, 2017] Li: “Similar to us”

11 • [May 5, 2017] Li: “We need to be first” 12 • [May 5, 2017] Li: “Their API is quite advanced and they have plugins to both Unity 13 and Unreal”

14 • [May 5, 2017] Li: “But fuck APIs for now, we need to create high end Pinmojis and 15 high-end interface”

16 • [May 5, 2017] Li: “I told everyone we do Deep [Learning], ahahahaha!” 17 • [May 5, 2017] Li: “Now everyone is nervous” 18 19 20 21 22 23 24 25 26 27 28 110 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13

14 Sadeghi’s group message, on Skype, leading up to SIGGRAPH 2017 RTL rehearsal: 15 • Sadeghi: “For the rehearsal, if we don’t generate a brand new avatar, then we have full 16 control and everything can be cached.” 17 18

19

20 Li’s group conversation with a Pinscreen employee, on “PinscreenTeamAll” thread, on Skype, 21 shared with Sadeghi and 14 other participants, on July 20, 2017, leading up to SIGGRAPH 22 RTL demo on August 1, 2017: 23 • [July 20, 2017] [a Pinscreen employee]: “In that case is it necessary to have the file 24 upload UI [User Interface]? Maybe just load the whole app [with] the thumbnails at the 25 bottom?” 26 • [July 20, 2017] [the Pinscreen employee]: “Plus with many images, if we fake the 27 loading time, it can add up” 28 111 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [July 20, 2017] Li: “I think file load is reasonable because it give[s] the people the 2 feeling the avatar is not pre-built”

3 • [July 20, 2017] Li: “We should give them a sense that it is computing” 4 • [July 20, 2017] Li: “If it’s just loaded it’s not impressive” 5 6 7 8 9 10 11 12 13 14

15

16 Sadeghi’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with 14 other 17 participants, on July 22, 2017, leading up to SIGGRAPH RTL demo on August 1, 2017, when 18 Sadeghi demonstrated a result of Pinscreen’s avatar generation and reported its speed:

19 • [July 22, 2017] Sadeghi: [Input image]

20 • [July 22, 2017] Sadeghi: [Output avatar]

21 • [July 22, 2017] Sadeghi: “The creation took ~90 seconds.” 22 23 24 25 26 27 28 112 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14

15 16 Sadeghi’s private messages to Li, on Skype, on July 22, 2017, which did not receive a written 17 response from Li: 18 • [July 22, 2017] Sadeghi: “Heya! 🙂🙂” 19 • [July 22, 2017] Sadeghi: “So for the live webcam avatar generation at RTL, are you 20 thinking we will compute everything from scratch (~90 seconds now with some risk for 21 a hairstyle miss) or we cache some stuff?” 22 23 24 25 26 27 28 113 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11 12 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 13 other participants, on July 28, 2017, leading up to SIGGRAPH RTL demo on August 1, 2017: 14 • [July 28, 2017] Li: “Oh no” 15 • [July 28, 2017] Li: “We are all screwed” 16 • [July 28, 2017] […] 17 • [July 28, 2017] Li: “Everyone will laugh at us” 18 • [July 28, 2017] Li: “😟😟” 19 20 21 22 23 24 25

26 … 27 28 114 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2

3

4 A Pinscreen officer’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with 5 Sadeghi and 14 other participants, on July 24, 2017, leading up to SIGGRAPH RTL demo on 6 August 1, 2017: 7 • [July 24, 2017] [a Pinscreen officer]: “Anyway … It’s important that we know 8 exactly who is using the webcam to generate the avatar” 9 • [July 24, 2017] [the Pinscreen officer]: “Since we’re just using pre-cached avatars” 10 11 12 13 14 15 16 17

18

19 In this subsection, we use fictional names, Alice, Bob, and Charlie to refer to three different 20 Pinscreen employees. 21 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 22 other participants, on July 17, 2017, leading up to SIGGRAPH 2017 RTL on August 1, 2017, 23 outlining some of the remaining tasks and the names of employees assigned to each task:

24 • [July 17, 2017] Li: […]

25 • [July 17, 2017] Li: “Hair models/avatars: Alice” 26 27 28 115 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11 Li’s group messages, on Skype, shared with Sadeghi and 7 other participants, on July 20, 2017, 12 leading up to SIGGRAPH RTL demo on August 1, 2017, outlining a remaining task and the 13 names of employees assigned to the task:

14 • [July 20, 2017] Li: “TODOs:”

15 • [July 20, 2017] Li: “* Creating all avatars, hair models, tweak for perfect hair 16 color [Alice / Bob]” 17 18 19 20 21 22 23

24 Alice’s messages, on Skype, on July 24, 2017, leading up to SIGGRAPH RTL demo on August 25 1, 2017: 26 • [July 24, 2017] Alice: “Hey” 27 • [July 24, 2017] Alice: 28 “I created a hair for Charlie’s avatar” 116 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6

7 Alice and Charlie’s group conversation, on “PinscreenTeamAll” thread, on Skype, shared with 8 Sadeghi and 14 other participants, on July 26, 2017: 9 • [July 26, 2017] Alice: “Oh [by the way] I also fixed my hair - I'll upload the updated 10 mesh” 11 • [July 26, 2017] Alice: “It looks like there are some intersections for your hair too, 12 should I fix?” 13 • [July 26, 2017] Charlie: “Thanks! Yeah this video shows the [current] status of the 14 avatars / hairs. So, anything you can improve in the asset would be great like the hair 15 intersection” 16 • [July 26, 2017] Charlie: “Oh and for my hair if you can lower it down a bit if it's 17 not too hard, that would be nice. (I [don’t] think my forehead is that large 🙂🙂)” 18

19 20 21 22 23 24 25 26 27 28 117 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11

12 Alice’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 13 other participant, on July 28, 2017: 14 • [July 28, 2017] Alice: “Charlie's new hair (with fewer intersections in the front) is in 15 the Dropbox folder here:” 16 • [July 28, 2017] Alice: 17 “https://www.dropbox.com/home/Pinscreen%20Team%20Folder/SIG17RTL/Ava 18 tarCandidates/AvatarData/[Charlie]_new” 19

20 21 22 23 24 25 26 27

28 118 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 In its SIGGRAPH Asia 2017 paper video, published on November 14, 2017, Pinscreen claimed 2 the speed of its avatar generation to be:

3 • Around 4 minutes (around 50 seconds in 5X fast forward) in its “high-quality” 4 configuration.

5 • “Less than a minute” without the “high-quality” features. 6 7 8 9 10 11

12

13 Li’s group messages to Sadeghi and other employees, on a Skype, on February 4, 2017: 14 • [February 4, 2017] Li: “Hello” 15 • [February 4, 2017] Li: “One of our tasks is to map segmented hair images to 3D 16 hairstyles” 17 • [February 4, 2017] Li: “Here is a paper that is kinda related” 18 • [February 4, 2017] Li: “But not exactly what we want” 19 • [February 4, 2017] Li: “Don’t share it” 20 • [February 4, 2017] […] 21 • [February 4, 2017] Li: [c118-f118_2-a523-paper-v1.pdf] 22

23 24 25 26 27 28 119 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7

8 … 9 10 11 12 13 14 15

16 Li’s private messages with Sadeghi, on Skype, on March 3, 2017: 17 • [March 3, 2017] Li: “Don’t share this paper” 18 • [March 3, 2017] Li: “It’s under review” 19 20 21 22 23 24

25 • 26 [March 3, 2017] Li: “Not from us” • 27 [March 3, 2017] Li: “Incremental work” • 28 [March 3, 2017] Li: “But the results are not bad” 120 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [March 3, 2017] Li: [c118-f118_2-a53-paper-v3.pdf] 2 • [March 3, 2017] Li: “Doing very similar stuff as we do” 3 • [March 3, 2017] Li: “But always good to see if there are some details that can be 4 used” 5 6 7 8 9 10 11 12 13 14 15

16 One of the under-review publications, from a competitor research group, which Li shared 17 within Pinscreen: 18 • Title: “Hairstyle Recognition Based on CNNs” 19 • File name: “c118-f118_2-a523-paper-v1.pdf” 20 • First page: 21 22 23 24 25 26 27 28 121 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

17 A post by a Research Scientist at Apple Inc., on Li’s Facebook wall, on October 25, 2017: 18 • [October 25, 2017] [a Research Scientist at Apple Inc.]: “I read at different places that you 19 claim some contributions to the iPhone X, e.g. ‘great article about our contributions to the 20 iPhone X’ or ‘developed as part of my PhD thesis.’ It is in my humble opinion a bald 21 claim as you do not know what is the technology behind this feature. It would be similar 22 if I was claiming some contribution to the Pinscreen tech which I don't. The word 23 contribution should be employed carefully and it would be better to avoid propagating 24 fake information based on some articles that do not have any evidence of what they are 25 claiming.” 26 27 28 122 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8

9 Li’s private messages to Sadeghi, on Skype, on February 27, regarding Venture Capitalists 10 (“VCs”): 11 • [February 27, 2017] Li: “Actually most VCs are assholes” 12 • [February 27, 2017] Li: “Hahahaha” 13 • [February 27, 2017] Li: “Never trust them” 14 15 16 17 18 19

20 Li’s private messages to Sadeghi, on Skype, on March 6, regarding Venture Capitalists 21 (“VCs”):

22 • [March 6, 2017] Li: “Also good VCs smell when [you] bullshit 🙂🙂” 23 • [March 6, 2017] Li: “Unless [you] bullshit like a pro” 24 • [March 6, 2017] Li: “Ahahahah!” 25 26 27 28 123 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6

7 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 8 other participants, on June 15, about Venture Capitalists (“VCs”): 9 • [June 15, 2017] Li: “Awesome” 10 • [June 15, 2017] Li: “In any case very important thing for startups, never trust VCs 11 regardless [of] how nice they are” 12 13 14 15 16 17 18 19

20 Li’s messages, on Skype, regarding Pinscreen and Softbank’s investment correspondances: 21 Li’s private message to Sadeghi, on Skype, on February 27, 2017:

22 • [February 27, 2017] Li: “We will have very important visits on 3/6 [March 6, 2017] 23 from Softbank, they will be checking our technology” 24 25 26 27 28 124 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7

8 Li’s group messages, on Skype, shared with Sadeghi and 8 other participants, on March 6, 9 2017: 10 • [March 6, 2017] Li: “We need to get these three guys working” 11 • [March 6, 2017] Li: “@[a Pinscreen employee]: Please pick the best possible hair” 12 • [March 6, 2017] Li: “If we get that we are golden” 13 14 15 16 17 18

19

20 • [March 6, 2017] Li: “Hao der” 21 • [March 6, 2017] Li: “It is related to our investment” 22 • [March 6, 2017] Li: “Let me tell you” 23 24 25 26 27 28 125 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7

8 Li’s group messages, on Skype, shared with Sadeghi and 8 other participants, on March 7, 9 2017: 10 • [March 7, 2017] Li: “Let’s generate the 3 models at really high quality” 11 • [March 7, 2017] Li: “@[the Pinscreen employee]: can you pick the best hair for the 12 3 photographs that I sent?” 13 14 15 16 17 18 19

20 • [March 7, 2017] Li: “I [don’t] have the names” 21 • [March 7, 2017] Li: “But it’s the Founder of Naver” 22 • [March 7, 2017] Li: “The CEO of Snow” 23 • [March 7, 2017] Li: “And GD from Bang” 24 25 26 27 28 126 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8

9 • [March 7, 2017] Li: “The hair has to be match perfectly to those they gave us” 10 11 12 13 14 15 16

17 Li’s private messages to Sadeghi, on Skype, shared with Sadeghi and 8 other participants, on 18 March 7, 2017: 19 • [March 7, 2017] Li: “We [want to] close the deal with them this week” 20 • [March 7, 2017] Li: “They want to invest 4M in us 😁😁” 21

22 23 24 25 26 27

28 127 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li disrespected Softbank on a group message, on “PinscreenTeamAll” thread, on Skype, shared 2 with Sadeghi and 14 other participants, on June 17, 2017, the day the investment agreement 3 between Pinscreen and Softbank was finalized, when he stated: 4 • [June 17, 2017] Li: “Pinscreen just fucked Softbank” 5 6 7 8 9 10 11 12

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 128 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT F 2 Li’s and Pinscreen’s Labor Law Violations 3 Li’s private message to Sadeghi, on Skype, on Father’s Day, on Sunday, June 18, 2017:

4 • [Father’s Day, Sunday, June 18, 2017] Li: “Please push the students more, they are 5 getting lazy and only work half of the day” 6 7 8 9 10 11

12 Wikipedia article on “Karōshi”: 13 • “Karōshi, which can be translated literally as ‘overwork death’ in Japanese, is 14 occupational sudden mortality.” 15 16 17 18 19 20

21 Wikipedia article on “Salaryman”: 22 • “Salaryman (Sararīman, salaried man) […] [is] expected to work long 23 hours, additional overtime […], and to value work over all else.” 24 • “Other popular notions surrounding salarymen include karōshi, or death from 25 overwork.” 26 27 28 129 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7

8 Li’s public posts, on Facebook, on May 23, 2017, referring to overworked Pinscreen 9 employees, who were passed out on couches at Pinscreen’s office, as “casualties”: 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

25 Li’s public posts, on Facebook, on July 23, 2017, referring to a Pinscreen student employee as 26 “Salariman [sic]” multiple times: 27

28 130 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13

14

15 Li’s post, on Facebook, on October 5, 2017, where Li paid tribute to Karoshi (i.e. death from 16 overwork) and stated: 17 • [October 5, 2017] Li: “Karoshi! Let me tell you! Sleep is for the weak!” 18 • [October 5, 2017] Li: [Li’s public Facebook post from January 22, 2009, stating “90 19 hours/week and loving it”] 20

21 22 23 24 25 26 27 28 131 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

22 23 Sadeghi’s private messages with a Pinscreen employee, on Skype, on August 7, 2017, regarding 24 the employee’s overtime hours: 25 • [August 7, 2017] Sadeghi: “Sorry you are not feeling well. Hope you get better soon 26 🙂🙂” 27 • [August 7, 2017] Sadeghi: “So you said your best estimate for average work hours 28 in the last 3 months leading upto RTL is 16 hours/day and 7 days a week?” 132 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 • [August 7, 2017] [a Pinscreen employee]: “Thanks!”

2 • [August 7, 2017] [the Pinscreen employee]: “Yes something like that” 3 • [August 7, 2017] Sadeghi: “Alright cool. Will talk to Hao [Li] today to make sure we are

4 fair to everyone. Especially the full-time employees 🙂🙂” 5 • [August 7, 2017] [the Pinscreen employee]: “Cool thanks.” 6 7 8 9 10 11 12 13 14 15

16 Sadeghi’s private messages with another Pinscreen employee, on Skype, on August 6, 2017 17 and August 7, 2017, regarding the employee’s overtime hours: 18 • [August 6, 2017] Sadeghi: “Hey my man [another Pinscreen employee], what would 19 be your best estimate on the average hours you worked per day/week in the past 3 20 months and upto RTL? 🙂🙂” 21 • [August 7, 2017] [the Pinscreen employee]: “I don’t know. Maybe around 100-120 22 hours/week? :-[ ” 23 • [August 7, 2017] Sadeghi: “Yes that’s a lot of hours. Alright cool. Will talk to Hao [Li] 24 today to make sure we are fair to everyone. Especially the full-time employees 🙂🙂” 25 26 27 28 133 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 Li’s messages, on Skype, in June of 2017, regarding a Pinscreen employee whom Li suspected 10 to have Autism Spectrum Disorder. The employee was the victim of Li’s bullying and 11 discrimination through verbal abuse, and harassment on multiple occasions: 12

13 Li’s group messages, on “NN Classifications” thread, on Skype, shared with Sadeghi and 5 14 other participants, on June 15, 2017, about the employee:

15 • [June 15, 2017]: Li: “Yes” 16 • [June 15, 2017]: Li: “Talk to him [the employee] in person, on Skype: he [the employee] 17 sometime decide[s] to fully ignore communication”

18 • [June 15, 2017]: Li: “Or does not have the ability to respond” 19 20 21 22 23 24 25 26

27 28 Li’s group messages, on “PinscreenTeamAll” thread, on Skype, shared with Sadeghi and 14 134 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 other participants, on June 23, 2017:

2 • [June 23, 2017]: Li: “[the employee] can [you] provide some updates and also reduce 3 the amount of time drawing? We are not fucking paying [you] for that!”

4 • [June 23, 2017]: Li: “Also make sure to throw the trash away like an adult” 5 6 7 8 9 10 11 12 13

14 Li’s group conversation with the employee, on “PinscreenTeamAll” thread, on Skype, shared 15 with Sadeghi and 14 other participants, on June 23, 2017: 16 • [June 23, 2017] [the employee]: “94.9% on hair length” 17 • [June 23, 2017] [the employee]: “Also sometimes a certain augmentation make[s] 18 some attributes better but others worse” 19 • [June 23, 2017] Li: “What are [you] doing different than [another Pinscreen 20 employee]’s framework? 21 • [June 23, 2017] Li: “Also do h [sic] only have one attribute?” 22 • [June 23, 2017]: Li: “[Can] [you] be more specific? I feel like I’m talking to a wall” 23 24 25 26 27 28 135 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11 Li’s group conversation with the employee, on “PinscreenTeamAll” thread, on Skype, on June 12 23, 2017: 13 • [June 23, 2017] [the employee]: “The main difference is in data augmentation / training 14 / testing etc.” 15 • [June 23, 2017] [the employee]: “The structure is the same” 16 • [June 23, 2017] Li: “Are u fucking shitting me???” 17 • [June 23, 2017] Li: “Can you do proper assessment, with every attribute” 18

19 20 21 22 23 24 25 26 27 28 136 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1

2 Li’s private messages with Sadeghi, on Skype, on June 23, 2017, about the employee: 3 • 4 [June 23, 2017]: Li: “We need to make him [the employee] report to us [Li and Sadeghi]” • 5 [June 23, 2017]: Li: “He [the employee] should not be autistic” • 6 [June 23, 2017]: […] • 7 [June 23, 2017]: Li: “Just make a serious face” 8 • [June 23, 2017]: Li: “Or talk like me 🙂🙂” • 9 [June 23, 2017]: Li: “He [the employee] needs to learn manners” • 10 [June 23, 2017]: Li: “That will be my new project now” 11 12 13 14 15 16

17 … 18 19

20

21 Li’s private messages with Sadeghi, on Skype, in March and April of 2017, regarding 22 Pinscreen’s CTO: 23 24 25 26 27 28 137 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 Li’s private messages with Sadeghi, on Skype, on March 3, 2017:

2 • [March 3, 2017] Sadeghi: “[Pinscreen’s CTO] is the only one who deals with Unity and 3 he is in a different time zone … not a good situation!”

4 • [March 3, 2017] Li: “Yes”

5 • [March 3, 2017] Li: “I told you, also he [the CTO] doesn’t work on weekends” 6 • [March 3, 2017] Li: “Bad hombre” 7 8 9 10 11 12 13 14 15

16 Li’s private messages with Sadeghi, on Skype, on March 4, 2017: 17 • [March 4, 2017] Li: “How can CTO be in Denmark 🙂🙂” 18 • [March 4, 2017] Li: “Makes no sense” 19 • [March 4, 2017] Sadeghi: “Yeah its almost impractical to work as a tab [sic] on the same 20 issues remotely … Given the distance and time difference.” 21 • [March 4, 2017] Li: “We actually agreed that he [Pinscreen’s CTO] would come” 22 • [March 4, 2017] Li: “But out of a sudden he [the CTO] had a child” 23 24 25 26 27 28 138 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10

11 Li’s group message, on Skype, shared with Sadeghi and 2 other participants, on April 1, 2017, 12 leading up to SIGGRAPH RTL submission due on April 4, 2017:

13 • [April 1, 2017] Li: “[Pinscreen’s CTO] is sick every deadline we have this year, 14 some folks are not around […]” 15 16 17 18 19

20 Li’s private messages with Sadeghi, on Skype, on April 17, 2017: 21 • [April 17, 2017] Li: “Check on status with [Pinscreen’s CTO]” 22 • [April 17, 2017] Li: “If we do not check with him, he [the CTO] is just doing 23 nothing” 24 • [April 17, 2017] Li: “If I see no progress on his side in the next month, I will fire 25 him [the CTO]” 26 27 28 139 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7

8 • [April 17, 2017] Li: “He [Pinscreen’s CTO] was super motivated and super productive” 9 • [April 17, 2017] Li: “But since SIGGRAPH deadline” 10 • [April 17, 2017] Li: “He [the CTO] suddenly is always not present” 11 • [April 17, 2017] Li: “Temporary is okay, but after 3-4 months, it is really starting to not 12 be fair to anyone else” 13 • [April 17, 2017] Li: “I understand he [the CTO] is having a baby, but I have never 14 seen someone who because of a baby cannot do any work for several months” 15 16 17 18 19 20 21 22 23 24

25 Sadeghi’s private message to Li, on Skype, on March 7, 2017, planning a detailed progress 26 report from Pinscreen’s CTO:

27 • [March 7, 2017] Sadeghi: “Maybe ask him [Pinscreen’s CTO] to share what he does 28 overall on the Weeklog AND in detail in a Google doc with you [Li] and me only. Add 140 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 that is because he [the CTO] works remotely etc etc. Make sure he [the CTO] doesn't

2 feel micromanaged or disrespected 🙂🙂” 3 4 5

6

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 141 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 EXHIBIT G 2 Sadeghi’s Employment Contract with Pinscreen 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 142 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

28 143 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

28 144 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 145 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 146 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

28 147 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 148 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 149 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 150 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

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28 151 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

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28 153 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

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27 28 155 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 156 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 157 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

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28 158 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 159 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.

1 THE END 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 160 VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL Dr. Iman Sadeghi v. Pinscreen Inc., et al.